Affirmation of Reasonable Suspicion and Probable Cause in Traffic Stops: Harris v. Melchor

Introduction

Rakeem Harris v. Hector Melchor et al., decided April 1, 2025 by the United States Court of Appeals for the Seventh Circuit, addresses the constitutional bounds of police traffic stops, searches, and detentions under 42 U.S.C. § 1983. The plaintiff, Rakeem Harris, sued three Bloomington, Illinois police officers and the City of Bloomington, alleging violations of his Fourth, First, Second and Fourteenth Amendment rights during two separate traffic stops in March and November 2021. Harris challenged (1) the lawfulness of stops based on minor equipment violations; (2) ensuing searches and seizures triggered by the odor of marijuana; (3) his temporary handcuffing and detention upon discovery of a handgun; and (4) an alleged burden on his free exercise of religion and Second Amendment rights. The district court granted summary judgment to the defendants, deeming their facts admitted and finding no reasonable jury could side with Harris. On appeal, the Seventh Circuit affirmed in full, clarifying the application of reasonable suspicion and probable cause in routine traffic encounters, as well as proper use of summary judgment procedures.

Summary of the Judgment

The Seventh Circuit affirmed the district court’s grant of summary judgment for Officers Melchor, Followell, and Roth, and the City of Bloomington. Key holdings include:

Minor traffic infractions—failure to signal and absence of a visible license plate—independently supplied reasonable suspicion to justify the March 2021 stop.
The November 2021 stop was valid under the same principle (improper license-plate display) and Harris’s placement of his plate inside the windshield did not defeat it.
Upon smelling what appeared to be marijuana, officers had probable cause to search both vehicle and person, even though the substance later proved to be hemp.
Detention and handcuffing for a brief weapons‐possession inquiry did not violate the Fourth Amendment when the driver failed to disclose his firearm license.
Harris’s First Amendment free‐exercise, Second Amendment, false arrest, malicious‐prosecution, intervention, and Monell claims all failed as a matter of law.
Procedurally, the district court properly deemed defendants’ statement of undisputed facts admitted after Harris failed to comply with Rule 56 and local rules, and it did not err in granting routine motions for extension of time.

Analysis

1. Precedents Cited

The opinion draws on a constellation of Supreme Court and Seventh Circuit decisions:

Muhammad v. Pearson, 900 F.3d 898 (7th Cir. 2018): Standard for viewing facts at summary judgment—non‐moving party’s evidence must be accepted if supported.
United States v. Jackson, 962 F.3d 353 (7th Cir. 2020): Reasonable suspicion supports a stop for any minor traffic violation.
United States v. Jackson, 103 F.4th 483 (7th Cir. 2024): Probable cause to search a vehicle based on odor of marijuana, even post‐legalization, where odor suggests driving under influence or improper packaging.
Rabin v. Flynn, 725 F.3d 628 (7th Cir. 2013): Officers may detain and handcuff an individual briefly to verify lawful weapons possession when the suspect does not voluntarily disclose license or permit.
Liteky v. United States, 510 U.S. 540 (1994): Adverse rulings do not establish judicial bias.
Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380 (1993): “Excusable neglect” standard for granting extensions of time.
Monell v. Department of Social Services, 436 U.S. 658 (1978): Municipal liability requires an underlying constitutional violation and evidence of a policy or practice causing it.

These authorities underpin the court’s view that ordinary traffic infractions furnish reasonable suspicion, the smell of marijuana supplies probable cause for a search, and brief detentions to verify gun permits are constitutional.

2. Legal Reasoning

The Seventh Circuit’s reasoning follows a two‐step path: first, procedural compliance; second, the merits of the constitutional claims.

Procedural Basis: Under Federal Rule of Civil Procedure 56(e) and local rules, Harris’s failure to respond with specific record citations meant the defendants’ statement of facts stood unchallenged. The court’s warning letter satisfied due process. Harris’s challenges to extensions of time and judge bias were properly rejected under established standards.
Substantive Claims:
- Reasonable Suspicion: Illinois law mandates signaling turns (625 ILCS 5/11-804(a)) and display of valid license plates (625 ILCS 5/3-413). Failure in either respect constitutes a traffic violation and justifies a stop. Even if Harris’s video showed a signal, his license‐plate cover alone sufficed.
- Probable Cause for Search: The odor of marijuana, indistinguishable from hemp, provided probable cause. Seventh Circuit precedent confirms that a reasonable officer’s fair inference of contraband odor legitimizes a search, regardless of later-exonerating results.
- Temporary Detention for Firearms Inquiry: Handcuffing and a brief weapons‐possession check are allowed when the driver does not disclose a valid permit. Officer safety and contemporaneous radio verification justify such measures.
- Other Claims: Malicious prosecution fails without any criminal charges; false arrest and failure-to-intervene collapse without constitutional violations; free exercise and Second Amendment claims lack a substantial burden or underlying injury; Monell liability collapses when no policy or practice caused a constitutional wrong.

3. Impact

Harris v. Melchor reinforces settled law in several respects:

It underscores that routine motor‐vehicle infractions, however minor, supply reasonable suspicion for investigatory stops.
It affirms that probable cause for searches may rest on sensory perceptions (the smell of marijuana), even post‐state legalization.
It confirms that brief weapons‐possession detentions and handcuffing are constitutional where officers cannot immediately verify permit status.
It highlights strict adherence to summary judgment procedures: unopposed facts become true if not supported by specific record evidence.

Lower courts in the Seventh Circuit will cite Harris for these propositions, and civil‐rights litigants will recognize the importance of robust evidentiary responses to summary judgment.

Complex Concepts Simplified

Reasonable Suspicion: A lowered standard than probable cause, requiring specific and articulable facts that a crime, even a minor traffic violation, has occurred.
Probable Cause: A reasonable belief, based on factual evidence and officer experience, that a crime has been or is being committed—sufficient to justify searches and arrests.
Summary Judgment (Rule 56): A court order granting judgment before trial when there is no genuine dispute of material fact. The nonmoving party must cite specific evidence; otherwise, the moving party’s facts are accepted.
Monell Liability: Municipalities are liable under § 1983 only if a policy, custom, or failure to train caused a constitutional violation.

Conclusion

Harris v. Melchor stands as a robust affirmation of established Fourth Amendment principles in the traffic‐stop context and a cautionary tale on procedural rigor in civil‐rights litigation. By confirming that minor equipment violations—failure to signal and improper license‐plate display—give rise to reasonable suspicion, that sensory perceptions of suspected contraband justify probable cause, and that brief detentions for weapons‐possession inquiries are permissible, the Seventh Circuit cements practitioners’ understanding of everyday police encounters. Equally important, the decision highlights the imperative for plaintiffs to comply with summary judgment rules or risk having their factual assertions treated as indisputable. This opinion will guide future courts, officers, and litigants in balancing law enforcement prerogatives with constitutional safeguards.