Case Explained: BRIAN PFALZGRAF v. RUSK COUNTY, WISCONSIN and BEN REISNER

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-12 The Seventh Circuit affirmed summary judgment on Plaintiff Brian Pfalzgraf’s claim that Deputy Ben Reisner’s protective frisk was unlawful but reversed summary judgment on his claim that the traffic stop was unconstitutionally extended. The court held that while the deputy lacked reasonable suspicion that Pfalzgraf was armed and dangerous to justify the initial pat-down, there were genuine disputes of material fact regarding whether specific observations—such as Pfalzgraf’s driving patterns, agitation, dilated pupils, dry mouth, inconsistent explanations, avoidance of police vehicles, and prior sightings of his truck at a known drug-trafficking residence—collectively provided reasonable suspicion of a separate drug offense. Under the standard established in *Rodriguez v. United States*, an officer may extend a traffic stop beyond the time required to address the initial violation only if they possess reasonable suspicion of other criminal activity; because the video footage did not clearly contradict the deputy’s assertions, this factual question must be resolved by a jury rather than decided as a matter of law at summary judgment. Regarding the frisk claim, the court affirmed that no individualized facts suggested Pfalzgraf posed a threat, noting that suspicion of drug impairment alone does not create a reasonable inference of weapon possession and that general contextual factors like time of day or location do not satisfy the *Terry* requirement for specific, articulable facts. Additionally, the court found that the deputy’s conduct violated clearly established law, denying qualified immunity on the frisk claim. The practical consequence of this ruling is that the case is remanded to the district court for further proceedings. Because the jury previously awarded damages without specifying which portion was attributable to the unlawful frisk versus the extended stop, and because the appellate court reversed liability on one of those two claims, the court vacated the $4,000 total damages award. The district court must now determine whether to conduct a new trial or apportion damages based on the remaining valid claim. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.