United States v. Eatman, No. 18-2525 (7th Cir. 2019)Annotate this Case
After an argument with his girlfriend, Eatman pounded on her apartment door, yelling to be let inside. Chicago police officers arrived in response to a 911 call, frisked Eatman, seized a loaded handgun, and placed him in handcuffs. Officers asked Eatman to produce the gun’s registration. His girlfriend refused to sign a police complaint. Officers took Eatman to the police station, where a background check revealed two prior felony convictions. Eatman was indicted for possession of a firearm by a felon, 18 U.S.C. 922(g)(1). Eatman unsuccessfully moved to suppress the gun. The district court found that the officers had reasonable suspicion when they found Eatman attempting to gain access to the apartment and that the officers arrested Eatman only after inquiring whether he had registration for the gun. Eatman entered a conditional guilty plea. On appeal, Eatman conceded the officers had reasonable suspicion to conduct a frisk but argued he was arrested without probable cause when he was handcuffed, so his felon status should be suppressed. The Seventh Circuit affirmed, finding the use of handcuffs on Eatman to be reasonable. The use of handcuffs was not an arrest but a method to de‐escalate the situation and allow the officers to investigate. The officers likely had probable cause to arrest Eatman for either the domestic battery or disturbing the peace.