## Facts

- Vaughn Neita operated a dog-grooming and rescue business in Chicago.
- Neita brought two dogs to the City’s animal-control facility: one that had killed another dog and one that became ill after giving birth.
- Neita alleged neither dog showed signs of abuse or neglect when surrendered.
- A city animal-control employee contacted police; officers arrested Neita and searched (1) his person, (2) his vehicle, and (3) his business premises.
- Neita was charged with animal-cruelty and related neglect offenses and was acquitted after a bench trial.
- Neita filed a § 1983 action alleging Fourth Amendment false arrest and unlawful searches; the district court dismissed the federal claims under Rule 12(b)(6) and declined supplemental jurisdiction over state-law claims.
- Neita appealed the dismissal of the § 1983 false-arrest and search claims.

## Issues

1. Whether the complaint plausibly alleged a § 1983 false-arrest claim by alleging arrest without probable cause.
2. Whether the complaint plausibly alleged Fourth Amendment violations based on warrantless searches of Neita’s person, vehicle, and business premises.
3. Whether the vehicle-search claim, added in an amended pleading, was time-barred or related back under Federal Rule of Civil Procedure 15(c).
4. Whether qualified immunity could be resolved for the individual defendants on the pleadings.

## Decision

- Reversed the Rule 12(b)(6) dismissal of the § 1983 false-arrest claim.
- Held the complaint plausibly alleged absence of probable cause given the alleged lack of evidence of mistreatment and the voluntary surrender of the dogs.
- Reversed dismissal of the search claims, including the search incident to arrest and the vehicle search, because the allegations plausibly described warrantless, unjustified searches.
- Held the vehicle-search claim related back to the original complaint under Rule 15(c) and was not barred by the statute of limitations.
- Held qualified immunity was not available at the pleading stage where the complaint alleged facts that, if true, placed defendants’ conduct outside lawful authority, including asserted statutory authority to search the business.
- Remanded for further proceedings.

## Legal Principles

- A § 1983 false-arrest claim requires plausible allegations that officers lacked probable cause for the arrest.
- At the motion-to-dismiss stage, courts accept well-pleaded factual allegations as true and draw reasonable inferences for the plaintiff.
- A search incident to arrest is vulnerable if the complaint plausibly alleges the arrest lacked probable cause and the search lacked independent justification.
- Under Rule 15(c), an amended claim relates back when it arises from the same conduct, transaction, or occurrence described in the original pleading.
- Qualified immunity generally cannot be granted on the pleadings when entitlement depends on disputed facts; warrantless searches are presumptively unreasonable absent a valid exception or lawful statutory inspection predicate.

## Conclusion

The Seventh Circuit held that Neita’s complaint plausibly alleged an arrest without probable cause and multiple unlawful searches, that the vehicle-search claim related back under Rule 15(c), and that qualified immunity could not be awarded on a bare complaint; it therefore reversed and remanded.


Neita v. City of Chicago, 830 F.3d 494 (7th Cir. 2016)