Vargas v. Guardiola serves as a significant ruling for municipalities navigating the legal implications of civil rights claims, especially those arising from traffic stops, ordinance enforcement, and administrative adjudication. This case underscores how municipalities can effectively defend against resource consuming lawsuits by maintaining well-documented administrative hearing records. The court’s application of Heck v. Humphrey, 512 U.S. 477 to bar several of Vargas’s claims hinged on the existence of clear and full records.

In Vargas, the Northern District of Illinois ruled that the Heck doctrine can apply to judgements from administrative proceedings on municipal ordinance violations. For local governments, the ruling offers both caution and an opportunity. Municipalities must ensure that administrative hearings meet due process standards and are clearly documented. If this is done properly, these records may later form the foundation of a legal defense.

The Case

Jesus Vargas (“Vargas” or “Plaintiff”), a 27-year-old man from Chicago, brought action against several Stone Park police officers (“Officers”), the Mayor, and the Village of Stone Park (“Village”) (collectively “Defendants”). The lawsuit was based on a series of traffic stops conducted by the Officers.

The Defendants moved for summary judgement on all of Vargas’s claims. First, the Defendants argued that the Heck doctrine bars Vargas’s Fourth Amendment claim regarding the February 2020 and April 2021 traffic stops. Under Heck, a court must dismiss a § 1983 action if a judgment in favor of the plaintiff in that action would necessarily imply the invalidity of his criminal conviction or sentence. Heck, 512 U.S. at 487. As a result, the Heck doctrine bars plaintiffs from making allegations that are inconsistent or incompatible with a previous conviction. However, on the February 2020 and April 2021 citations, Vargas was involved in administrative hearings and not criminal ones. The Seventh Circuit has reserved judgement on “whether an administrative proceeding or a finding of a violation of a city ordinance triggers the Heck bar.” Justice v. Town of Cicero, 577 F.3d 768, 773 (7th Cir. 2009). In two past decisions, the Seventh Circuit has declined to apply the Heck doctrine to findings in administrative hearings. However, these cases involved incomplete records and sparse information about earlier administrative proceedings. See Kuhn v. Goodlow, 678 F.3d 552, 555 (7th Cir. 2012); Justice, 577 F.3d at 773. The Court distinguished this case by noting that Vargas’s administrative hearings were well documented. The record documented the final judgment, and there was an audio recording of the April hearing.

As a result of this finding, the Court held that many of Vargas’s claims were Heck-barred. Vargas’s Fourth Amendment claims related to the February 2020 and April 2021 stops could not proceed because they contradicted the finding of the administrative law judge. For the February 2020 stop, Vargas argued that the Officers lacked reasonable suspicion and probable cause, claiming both of his headlights were on at the time of the stop and disputing that the vape pen and marijuana were in plain view. However, the administrative judge had already found that Vargas was driving with only one headlight and upheld the citations based on the Officers’ observations. Because these findings were part of a final administrative judgment, Vargas’s claims directly contradicted those conclusions and were therefore barred under Heck.

For the April 2021 stop, Vargas similarly denied the underlying facts, claiming he had not driven past Mayor Mazzulla’s home while playing loud music or shouting profanities. However, he had been convicted of disorderly conduct at a bench trial based on those very facts, and the conviction was upheld on appeal. As a result, Vargas’s allegations that were inconsistent with that conviction were also barred under Heck.

The Court also granted summary judgment for the Defendants on Vargas’s failure to intervene, conspiracy, and due process claims. Claims for failure to intervene and conspiracy require constitutional rights violations. See Gill v. City of Milwaukee, 850 F.3d 335, 342 (7th Cir. 2017); Beaman v. Freesmeyer, 776 F.3d 500, 510 (7th Cir. 2015); Harper v. Albert, 400 F.3d 1052, 1064 (7th Cir. 2005); Watkins v. Phillips, No. 22 C 7341, 2025 WL 919612, at *10 (N.D. Ill. Mar. 26, 2025). Because Heck barred the Fourth Amendment claims relating to the February 2020 and April 2021 stops, and no genuine factual dispute existed concerning the other stops, no constitutional claims existed. For this reason, the Court granted summary judgment in favor of the Defendants.

Likewise, Vargas’s fabricated evidence claim (later identified as a due process violation claim) was in part based on the Fourth Amendment. First, the Court noted that Vargas’s claim identified no fabricated evidence other than the allegedly false accounts that Officers relied on for the various stops. The Defendants argued that wrongful detention, “whether based on fabricated evidence or some other defect – sound[s] in the Fourth Amendment.” Lewis v. City of Chicago, 914 F.3d 472, 479 (7th Cir. 2019). Vargas acknowledged that his fabricated evidence claims arise, if at all, under the Fourth Amendment. As such, and for the reasons already stated, the Court also granted summary judgment for the Defendants on this claim.

In granting summary judgement on the remaining counts, the Court reiterated that probable cause existed, no genuine factual dispute existed, and Heck barred the assertion of certain claims. 

Best Practice Tips

The Vargas court heavily relied on the Village of Stone Park’s audio recordings and clear final judgment records in applying the Heck doctrine. Historically, courts have been hesitant to use findings from administrative hearings due to a lack of information regarding the parties’ arguments, the findings on those arguments, and the overall disposition of the case. With the costs associated with litigation rising, and award amounts in successful civil cases reaching millions of dollars, it is important that municipalities use the tools available to them to avoid financial hardship. For this reason, we recommend that municipalities record their administrative hearings through video or audio recording. Additionally, administrative hearing judges need to keep clear records of their findings and final judgments.

Authored by:

not-pictured: Zachary Frye