The ruling in Crampton v. Little et al. grants summary judgment to the officers on the plaintiff’s false arrest claim, shielding them from liability for the arrest itself. However, the court found that the right to be free from force that knowingly inflicts pain on a cooperative arrestee with known medical issues was clearly established, permitting the excessive force claim to proceed.
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 passenger in a red Ford F-350 driven by Steven Garland. Police responded to a call reporting an intoxicated male attempting to leave in the vehicle.
Officers Samuel Little, Tom Wiley, and Eric Dusenberry approached the truck. The officers’ affidavits state that Crampton was intoxicated, used profanity, and refused to exit the vehicle. They allege that when they attempted to speak with him, he rolled up the window, striking Officer Dusenberry with the door.
Crampton’s affidavits and those of eyewitnesses present a different account. He states he never attempted to drive away, did not swear at the officers, and provided his name and address. He claims he closed the door thinking he could leave, and that the officers never instructed him to exit before forcibly pulling him from the truck.
Crampton alleges that after identifying himself as having bad shoulders and requesting front handcuffs, Officers Little and Dusenberry pinned him against the truck, yanked his arms behind his back, and raised them, causing him to cry out in pain. He subsequently sought medical treatment for injuries to his wrists, elbows, arms, and shoulders.
Regarding the false arrest claim, Judge Darrow held that the officers were entitled to qualified immunity. The court noted that Crampton indisputably struck Officer Dusenberry with the truck door, providing probable cause for an arrest for battery. The court found it was not clearly established that arresting him for this minor offense violated the Constitution, regardless of whether he was ultimately charged with battery.
On the excessive force claim, the court denied qualified immunity for Officers Little, Dusenberry, and Wiley. The court reasoned that if Crampton’s account is credited, the officers used force that inflicted unnecessary pain on a compliant individual with known medical issues. The court held that this right was clearly established by Seventh Circuit precedent.
The court also rejected the officers’ argument that Crampton needed expert medical testimony to prove causation for his injuries. Judge Darrow wrote that a typical juror could draw a causal line between the discrete instance of force and Crampton’s localized injuries, noting the close temporal proximity to his medical visit.
The case proceeds to trial on the excessive force claim. The officers had previously moved for summary judgment on all claims, arguing they used reasonable force and that Crampton could not prove causation. The court’s order was issued on April 21, 2026.