Manuel Galvan v. Thomasnorberg, et al

Before EASTERBROOK, Chief Judge, and FLAUM and MANION, Circuit Judges.

Manuel Galvan filed a § 1983 action against Chicago police officers Thomas Norberg and Alan Lucas, seeking damages arising from a traffic stop, a vehicle search, and an arrest. Galvan contends that the officers lacked probable cause, whereas the officers maintain that they were following up on an anonymous tip that Lucas had received. After the jury returned a verdict in favor of defendants Norberg and Lucas, Galvan moved for a new trial. Judge Shadur granted the motion but without giving defendants an opportunity to respond. He ruled that the verdict was against the manifest weight of the evidence, reasoning that Lucas had fabricated the tip and that the other officers offered false testimony to support this fabrication. Judge Shadur then recused himself, and the case was reassigned to Judge Chang. Defendants moved to reconsider the new trial order. Judge Chang granted their motion and reinstated the verdict.