O R D E R
David Jackson and his wife Nickole brought this lawsuit alleging constitutional violations arising out of his arrest and criminal convictions. See 42 U.S.C. § 1983. The district court dismissed the Jacksons' complaint for failure to state a claim. We affirm. We recite the facts as alleged in the Jacksons' complaint, drawing all reasonable inferences in their favor. Hess v. Garcia, 72 F.4th 753, 756-57 (7th Cir. 2023). In 2018, police officers—based on a tip that Mr. Jackson was engaging in sexual misconduct with a minor—went to the Jacksons' home with an arrest warrant for him. They entered the home and "destroyed portions" of it. The officers detained Mrs. Jackson and
"forcefully prevented" her from contacting anyone by phone. They asked her about Mr. Jackson's whereabouts, and she told them he was at work, where he was then arrested. Mr. Jackson was interrogated by Detective Robert Brazil. Brazil declined to investigate Mr. Jackson's alternative explanations. Mr. Jackson maintained his innocence and described being told by the minor that she had been molested by a cousin and not him. During the interrogation, Mr. Jackson was deprived of food and water. And while in custody, he was forced to sleep on bare concrete. The police hurled racial epithets at Mr. Jackson and made him "relive abuses he suffered as a child." The police department posted on Facebook that Mr. Jackson had opened a board game business "to attract children and have sex with the children."
Soon after his release from custody, Mr. Jackson was again arrested based on accusations of sex crimes, this time from two other individuals. Mr. Jackson asserts that a proper police investigation would have exculpated him. Later, after he had been brought to the jail, guards ignored assaults against him, denied him medical care for severe pain, and placed him in solitary confinement. In the months that followed, evidence of Mr. Jackson's innocence was concealed by Brazil and Richard Zormier, the police chief of Hobart, Indiana.
In February 2020, the Jacksons sued Brazil and Zormier for constitutional violations arising out of Mr. Jackson's arrest; Mrs. Jackson's detention; Brazil's interrogation and investigations; the police department's failure to train officers in proper investigative techniques; Brazil and Zormier's concealment of material evidence; and the police officers' use of racial epithets. The Jacksons also sued Brazil and Zormier for violations of state law.
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After Brazil and Zormier did not timely respond to the complaint, the Clerk of Court for the Northern District of Indiana entered default for the Jacksons. But a month later, the district court set aside the entry of default, determining that Brazil and Zormier had shown good cause for their delayed response—the deadline had been overlooked amid personnel turnover in Hobart's law department and restructuring of its case-management system.
A few weeks later, over the Jacksons' objection, the court granted Brazil and Zormier's motion to stay the proceedings pending the outcome of Mr. Jackson's criminal cases.
In February 2021, Mr. Jackson pleaded guilty in three separate cases to charges of sexual misconduct with a minor. He was sentenced to three years' probation, which was later revoked. At the defendants' request, the district court lifted the stay in 2024, finding that the claims in this case did not relate to Mr. Jackson's only remaining appeal, which challenged plea-agreement terms concerning his sentence. The court later denied the Jacksons' motion to reimpose the stay, reiterating that the claims here did not bear on the remaining appeal.
The district court granted leave for the Jacksons to amend their complaint to add more defendants. Their proposed amended complaint, however, added over fifty new defendants and other unrelated claims, so the district court rejected it. The district court also denied the Jacksons' repeated motions for appointment of counsel, concluding that the case was not overly complex and that the Jacksons were competent to litigate their claims.
The court ultimately granted Brazil and Zormier's motion to dismiss the case for failure to state a claim. The court determined that the Jacksons' wrongful-arrest and concealment-of-evidence claims were barred by Heck v. Humphrey, 512 U.S. 477, 486-87 (1994), because they would imply the invalidity of Mr. Jackson's convictions. Regarding Detective Brazil, the court concluded that the Jacksons' allegations against him were too unclear to state a claim. As for Mrs. Jackson's detention during the execution of the arrest warrant for Mr. Jackson, the court determined that the complaint did not adequately allege that the detention was unreasonable. Based on this determination, the court declined to weigh in on a question that had divided the circuits: whether the categorical exception in Michigan v. Summers, 452 U.S. 692, 705 (1981)—permitting a bystander not suspected of wrongdoing to be detained during the execution of a search warrant—extends to the execution of an arrest warrant. The court added that the
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complaint was too vague to allege plausible claims of municipal liability, racial discrimination, excessive force, or failure to consider medical and dietary needs. The court then relinquished supplemental jurisdiction over the state law claims and dismissed them without prejudice. See 28 U.S.C. § 1367.
On appeal, the Jacksons first challenge the district court's dismissal of their Fourth Amendment claim, arguing that Summers does not permit officers to detain a bystander on the premises while they execute an arrest warrant. But this appeal does not require us to weigh in on the question of Summers' extension to the arrest-warrant context, compare United States v. Mastin, 972 F.3d 1230, 1238 (11th Cir. 2020) (categorically extending Summers); Cherrington v. Skeeter, 344 F.3d 631, 638 (6th Cir. 2003) (same); Freeman v. Gore, 483 F.3d 404, 412 (5th Cir. 2007) (same); with Sharp v. County of Orange, 871 F.3d 901, 912-15 (9th Cir. 2017) (declining to categorically extend Summers but noting that bystander detentions will surely be reasonable in some circumstances), because the complaint does not state a claim that the de minimis detention was unreasonable under the Fourth Amendment. See Samson v. California,
547 U.S. 843, 855 n.4 (2006); Maryland v. Buie, 494 U.S. 325, 331 (1990). As the district court noted, the Jacksons' threadbare recital of Mrs. Jackson's detention was insufficient to state such a claim.
Next, the Jacksons argue that the district court erred in setting aside the entry of default against the defendants because doing so prejudiced their ability to seek redress. But given our preference for determinations on the merits over default judgments, see Escamilla v. United States, 62 F.4th 367, 372 (7th Cir. 2023), the district court appropriately exercised its discretion in determining that the city (1) had good cause for the error based on the restructuring in its legal office and (2) took prompt steps to correct the mistake, entering appearances and filing the motion to set aside the entry of default less than two weeks after it was entered.
The Jacksons also challenge the district court's grant of a stay, arguing that the stay caused them "manifest injustice" by delaying the resolution of their claims and impeding their ability to procure evidence and witnesses. But the district court appropriately exercised its discretion when it evaluated the competing interests, determined that much of the civil suit stemmed from the ongoing criminal prosecution, and concluded that a stay would not prejudice the Jacksons. See United States v. Kordel,
397 U.S. 1, 12 n.27 (1970). Next, the Jacksons challenge the denial of their requests for counsel and argue that their case was too complex for them to litigate because of their mental and physical
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health conditions. But the court reasonably determined that the Jacksons were capable of presenting the legal issues here, having filed many motions that contained well- organized arguments with appropriate legal citations. See Pruitt v. Mote, 503 F.3d 647, 654-55 (7th Cir. 2007) (en banc).
The Jacksons also challenge the denial of their motion to amend the complaint and urge that the court simply should have severed the unrelated claims. But the Jacksons' proposed amended complaint sought to add over 50 new defendants and replace their allegations with unrelated ones that extended over seven years and mostly concerned the revocation of Mr. Jackson's probation. District judges should reject complaints attempting to bring unrelated claims against different defendants. See, e.g., Owens v. Evans, 878 F.3d 559, 566 (7th Cir. 2017). Further, the proposed amended complaint would have vastly altered the case's scope, causing substantial delay and prejudice to the defendants, who had filed a motion to dismiss. See Airborne Beepers & Video, Inc. v. AT & T Mobility LLC, 499 F.3d 663, 667 (7th Cir. 2007); Zimmerman
v. Bornick, 25 F.4th 491, 494 (7th Cir. 2022). We have reviewed the Jacksons' challenge to the dismissal of their other claims (race discrimination, municipal liability, failure to disclose exculpatory evidence, excessive force, denial of medical care, cruel and unusual punishment), but those arguments on appeal are underdeveloped and do not merit further discussion.
AFFIRMED
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