The dispute centers on an encounter on June 21, 2023, at Grease Monkeys Sports Bar and Grill in Colona, Illinois. Plaintiff John Crampton, III, was a patron who had become intoxicated and could not safely drive. When he attempted to leave in his red Ford F-350, a bystander reported him to police. Officers Samuel Little, Eric Dusenberry, and Tom Wiley responded to the scene.
The officers and Crampton present conflicting accounts of the arrest. The officers allege Crampton was uncooperative, used profanity, and resisted when they attempted to remove him from the vehicle. Crampton contends he complied with questions, did not resist, and was forcibly pulled from the truck and handcuffed behind his back despite informing the officers of preexisting shoulder injuries.
U.S. District Judge Sara Darrow granted summary judgment to the officers on Crampton's false arrest claim, ruling they were entitled to qualified immunity. The court noted that Crampton struck Officer Dusenberry with the truck door, providing probable cause for a battery arrest regardless of whether the officers believed that specific charge was valid.
However, the court denied qualified immunity on the excessive force claim. Judge Darrow held that it was clearly established law that officers may not knowingly use handcuffs in a manner that inflicts unnecessary pain on an arrestee who presents little or no risk of flight or threat of injury. Additionally, when an arrestee informs officers of a preexisting injury or medical condition, the officers are obligated to consider that information in determining whether handcuffing is appropriate.
The court also denied immunity for Officer Wiley on a failure-to-intervene claim. The court held that a jury could reasonably conclude Wiley had an opportunity to intervene, as he was present at the scene and observed the actions of his colleagues.
The officers also argued that Crampton failed to prove causation for his injuries without expert medical testimony. The court rejected this, ruling that expert testimony is not required when a typical layperson can draw a causative line between the injuries and the force used.
Crampton's state court charges of resisting a peace officer were previously dismissed because there was no underlying offense for which he was subject to arrest. His federal lawsuit proceeds on the remaining excessive force and failure-to-intervene claims.