CA7: Not a Fourth Amendment violation to physically arrest for a fine only traffic infraction

It is not a Fourth Amendment violation to physically arrest for a fine only traffic infraction. Williams v. Brooks, 2016 U.S. App. LEXIS 68 (7th Cir. Jan. 5, 2016):

Williams argues that there is a genuine issue of material fact as to whether he committed a traffic infraction such that Officer Brooks had probable cause to stop and arrest him. The Fourth Amendment prohibits unreasonable searches and seizures, but the existence of probable cause renders traffic stops and resulting warrantless arrests permissible. Jones v. City of Elkhart, 737 F.3d 1107, 1114 (7th Cir. 2013) (noting that probable cause is an absolute defense to false arrest claims in § 1983 actions). “When a police officer reasonably believes that a driver has committed a minor traffic offense, probable cause supports the stop.” Id. (citation and internal quotation marks omitted); see also United States v. Hernandez-Rivas, 513 F.3d 753, 759 (7th Cir. 2008) (concluding that when an officer observes a vehicle changing lanes without signaling, the officer has probable cause for a traffic stop). Additionally, it is “not a violation of the Fourth Amendment to arrest an individual for even a very minor traffic offense.” Jackson v. Parker, 627 F.3d 634, 639 (7th Cir. 2010); see also Atwater v. City of Lago Vista, 532 U.S. 318, 323, 121 S. Ct. 1536, 149 L. Ed. 2d 549 (2001) (holding that the Fourth Amendment does not forbid “a warrantless arrest for a minor criminal offense, such as a misdemeanor seatbelt violation punishable only by a fine”).