Guzman v. Bonnstetter, No. 10-1858 (7th Cir. 2012)
Annotate this CaseGuzman, seven-and-a-half months pregnant, home alone, in bed, heard the doorbell and knocking. She walked toward the door. Sergeant Bonnstetter of the Chicago Police Department burst through the door. Officers wearing body armor rushed in, many with guns drawn. Guzman, fearful and crying, was ordered to lie face down on the floor. When she tried to position herself more comfortably, Rojas forced her down, pressing her pregnant belly against the floor. The Joint Gang Task Force executed a warrant, searching the apartment for about an hour. Guzman sued. The district court entered summary judgment in her favor, finding Bonnstetter and Rojas liable. At a damages-only trial, Guzman proved medical expenses. The court allowed defendants to testify that the search was legal and reasonable and that others might have caused Guzman’s injuries. The court instructed the jury that Guzman had to prove that Bonnstetter and Rojas were “personally involved” and could not be held “liable” for the conduct of “other employees.” The court instructed the jury to award nominal damages if Guzman failed to prove that her damages were the direct result of defendants’ conduct. Guzman was awarded $1. The Seventh Circuit reversed. Defendants’ theory of the case and evidence and the instruction likely confused the jury.
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