Case: Wilkins v. City of Chicago

1:23-cv-04072 | U.S. District Court for the Northern District of Illinois

Filed Date: June 26, 2023

Case Ongoing

Clearinghouse coding complete

Case Summary

This is a case about the Chicago Police Department’s (CPD) alleged pattern and practice of race-based and discriminatory police practices in traffic stops conducted since 2016. On June 26, 2023, five plaintiffs who had been repeatedly stopped by CPD officers, on what they claimed was limited suspicion, filed this putative class action lawsuit in the U.S. District Court for the Northern District of Illinois. The plaintiffs alleged unlawful race and national origin discrimination in violation of …

This is a case about the Chicago Police Department’s (CPD) alleged pattern and practice of race-based and discriminatory police practices in traffic stops conducted since 2016. On June 26, 2023, five plaintiffs who had been repeatedly stopped by CPD officers, on what they claimed was limited suspicion, filed this putative class action lawsuit in the U.S. District Court for the Northern District of Illinois. The plaintiffs alleged unlawful race and national origin discrimination in violation of the Equal Protection Clause, Title VI of the Civil Rights Act of 1964, and the state constitution and Illinois Civil Rights Act of 2003. The putative class included Black and Latino drivers who were subjected to CPD’s mass traffic stop program. Represented by the ACLU of Illinois and private counsel, the plaintiffs sought 1) class certification, 2) a declaratory judgment, 3) a permanent injunction prohibiting defendants from continuing their mass traffic stop program and requiring them to submit a plan detailing how they would modify their practices, as well as how they would better screen, train, supervise, monitor, and discipline CPD officers to eliminate and prevent the alleged civil rights violations, and 4) attorneys’ fees and costs.

In their complaint, the plaintiffs alleged that CPD made more than 1 million traffic stops between 2016 and 2022 based on suspect evidence of minor violations that took direct aim at Black and Latino Chicagoans, subjecting them to discrimination on the basis of race and national origin. They further alleged that this mass traffic stop program, purportedly a campaign to fight crime in Chicago, was in fact an intentional effort to racially profile millions of Black and Latino drivers and to discriminate on the basis of race and national origin.  Further, the plaintiffs alleged that the CPD failed to screen, train, supervise, and hold officers and supervisors accountable for discriminatory traffic stops, and for failing to report tens of thousands of traffic stops, as required, to the Illinois Department of Transportation. In additional, the plaintiffs alleged that the City of Chicago and its policymakers, including the Mayor and the Superintendent of the Chicago Police Department, either developed, implemented, enforced, encouraged, and sanctioned Chicago PD’s policy and practice of mass traffic stops, frisks and searches of the plaintiffs and proposed class members, or were deliberately indifferent to the unconstitutional acts.

The City and CPD filed a motion to dismiss on September 25, 2023. The motion asserted that the CPD, a municipal entity, was not suable (essentially that claims against the CPD were properly asserted against the City of Chicago). They also asserted that plaintiffs' claims fell outside of the two-year statute of limitations and that plaintiffs did not adequately make factual allegations to support their assertion that CPD acted with a discriminatory purpose. Furthermore, the City claimed that plaintiffs claims under the Illinois State Constitution did not entitle plaintiffs to relief as it didn't provide plaintiffs with a private right of action. They also sought to strike 29 paragraphs from plaintiffs' complaint, primarily related to plaintiffs' statements about CPD's stop-and-frisk programs, a motion plaintiffs opposed on November 14, 2023. Plaintiffs asserted that after the ACLU sued and settled with the City for CPD's stop-and-frisk program widely practiced from the 2000s onwards in 2015, CPD's racially-motivated harassment pivoted to mass traffic stops of Black and Latino drivers.

While the court considered defendants' motion to dismiss, the parties negotiated a confidentiality order applicable to the data plaintiffs had requested from the city.  

On June 7, 2024, plaintiff filed a motion to intervene in Illinois v. City of Chicago (1:17-cv-06260). The parties in Illinois v. City of Chicago were in the process of negotiating a consent decree regarding CPD's mass traffic stop program and sought to have their interests in injunctive relief represented. 

On June 10, 2024, the court granted in part and denied in part defendants' motion to dismiss and denied the motion to strike. The motion to strike was denied on the basis that defendants failed to meet their burden to demonstrate that the challenged paragraphs were devoid of merit, unworthy of consideration, and unrelated to the controversy. Plaintiffs voluntarily dismissed their claim under the Illinois Constitution. The court dismissed plaintiffs' Title VI claims because Chicago, as a municipality, was not a "program" or "activity" receiving federal funding under the scope of Title VI and CPD lacked an independent legal existence as a government department controlled by the city. The court held that plaintiffs' Equal Protection and Illinois Civil Rights Act claims could proceed. Plaintiffs were given leave to ament their complaint by June 17, 2024.  

Summary Authors

Simran Takhar (6/29/2023)

Hannah Juge (6/13/2024)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/67528980/parties/wilkins-v-city-of-chicago/


Judge(s)
Attorney for Plaintiff

Ballesteros, Henry Atticus (Illinois)

Baskin, Cate (Illinois)

Block, Alexandra Kay (Illinois)

Attorney for Defendant

Ahn, Joan E (Illinois)

Cross, Thomas Hudson (Illinois)

show all people

Documents in the Clearinghouse

Document
1

1:23-cv-04072

Class Action Complaint for Declaratory and Injunctive Relief

June 26, 2023

June 26, 2023

Complaint
76

1:23-cv-04072

Memorandum Opinion and Order

June 10, 2024

June 10, 2024

Order/Opinion

2024 WL 2892840

87

1:23-cv-04072

First Amended Class Action Complaint for Declaratory and Injunctive Relief

July 2, 2024

July 2, 2024

Complaint
96

1:23-cv-04072

City of Chicago's Answer and Affirmative Defenses to First Amended Class Action Complaint for Declaratory and Injunctive Relief

Sept. 20, 2024

Sept. 20, 2024

Pleading / Motion / Brief

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/67528980/wilkins-v-city-of-chicago/

Last updated Jan. 30, 2025, 10:25 p.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT Class Action Complaint for Declaratory and Injunctive Relief filed by Eric Wilkins, Jos Manuel Almanza, Jr, Essence Jefferson, Mahari Bell, Jacquez Beasley; Filing fee $ 402, receipt number AILNDC-20772563.(Block, Alexandra) (Entered: 06/26/2023)

June 26, 2023

June 26, 2023

Clearinghouse
2

CIVIL Cover Sheet (Block, Alexandra) (Entered: 06/26/2023)

June 26, 2023

June 26, 2023

RECAP
3

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by Alexandra Kay Block (Block, Alexandra) (Entered: 06/26/2023)

June 26, 2023

June 26, 2023

PACER
4

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by Joshua Mitchell Levin (Levin, Joshua) (Entered: 06/26/2023)

June 26, 2023

June 26, 2023

PACER
5

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by Henry Atticus Ballesteros (Ballesteros, Henry) (Entered: 06/26/2023)

June 26, 2023

June 26, 2023

PACER

CASE ASSIGNED to the Honorable Mary M. Rowland. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (smb, )

June 27, 2023

June 27, 2023

PACER

case assigned

June 27, 2023

June 27, 2023

PACER

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. (smb, )

June 27, 2023

June 27, 2023

PACER

clerk's notice

June 27, 2023

June 27, 2023

PACER
6

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by Sheldon Louis Solow (Solow, Sheldon) (Entered: 06/28/2023)

June 28, 2023

June 28, 2023

PACER
7

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-20784163. (Freedman, John) (Entered: 06/28/2023)

June 28, 2023

June 28, 2023

PACER
8

MINUTE entry before the Honorable Mary M. Rowland: Motion to appear pro hac vice by John A. Freedman 7 is granted. Counsel is reminded to become familiar with this court's local rules. Mailed notice. (dm, ) (Entered: 06/29/2023)

June 29, 2023

June 29, 2023

PACER
9

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by John A. Freedman (Freedman, John) (Entered: 06/29/2023)

June 29, 2023

June 29, 2023

PACER
10

MINUTE entry before the Honorable Mary M. Rowland: On or before 9/8/23, the parties shall file a joint initial status report. A template for the Initial Status Report, setting forth the information required, may be found at http://www.ilnd.uscourts.gov/Judges.aspx by clicking on Judge Rowland's name and then again on the link entitled 'Initial Status Conference.' The litigants are further ordered to review all of Judge Rowland's standing orders and the information available on her webpage. The court will enter a scheduling order in response. Mailed notice. (dm, ) (Entered: 06/30/2023)

June 30, 2023

June 30, 2023

PACER
11

MOTION by Attorney H. Atticus Ballesteros to withdraw as attorney for Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins. No party information provided (Ballesteros, Henry) (Entered: 07/18/2023)

July 18, 2023

July 18, 2023

PACER
12

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-20842250. (Davis, Joshua) (Entered: 07/18/2023)

July 18, 2023

July 18, 2023

PACER
13

MINUTE entry before the Honorable Mary M. Rowland: Motion to withdraw appearance of Atticus Ballesteros as attorney 11 is granted. The appearance of H. Atticus Ballesteros is withdrawn as counsel of record and he is removed from the Electronic Case Filing Service List. Mailed notice. (dm, ) (Entered: 07/19/2023)

July 19, 2023

July 19, 2023

PACER
14

MINUTE entry before the Honorable Mary M. Rowland: Motion to appear pro hac vice by Joshua M. Davis 12 is granted. Counsel is reminded to become familiar with this court's local rules. Mailed notice. (dm, ) (Entered: 07/19/2023)

July 19, 2023

July 19, 2023

PACER
15

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-20843585. (Derocher, Patrick) (Entered: 07/19/2023)

July 19, 2023

July 19, 2023

PACER
16

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by Joshua M. Davis (Davis, Joshua) (Entered: 07/19/2023)

July 19, 2023

July 19, 2023

PACER
17

WAIVER OF SERVICE returned executed by Eric Wilkins, Jose Manuel Almanza, Jr., Essence Jefferson, Mahari Bell, Jacquez Beasley. City of Chicago waiver sent on 6/27/2023, answer due 8/28/2023. (Block, Alexandra) (Entered: 07/19/2023)

July 19, 2023

July 19, 2023

PACER
18

WAIVER OF SERVICE returned executed by Eric Wilkins, Jose Manuel Almanza, Jr., Essence Jefferson, Mahari Bell, Jacquez Beasley. Chicago Police Department waiver sent on 6/27/2023, answer due 8/28/2023. (Block, Alexandra) (Entered: 07/19/2023)

July 19, 2023

July 19, 2023

PACER
19

MINUTE entry before the Honorable Mary M. Rowland: Motion to appear pro hac vice by Patrick Derocher 15 is granted. Counsel is reminded to become familiar with this court's local rules. Mailed notice. (dm, ) (Entered: 07/20/2023)

July 20, 2023

July 20, 2023

PACER
20

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by Patrick Derocher (Derocher, Patrick) (Entered: 07/20/2023)

July 20, 2023

July 20, 2023

PACER
21

ATTORNEY Appearance for Defendants Chicago Police Department, City of Chicago by Michael P. Sheehan (Sheehan, Michael) (Entered: 08/22/2023)

Aug. 22, 2023

Aug. 22, 2023

PACER
22

ATTORNEY Appearance for Defendants Chicago Police Department, City of Chicago by Allan T. Slagel (Slagel, Allan) (Entered: 08/22/2023)

Aug. 22, 2023

Aug. 22, 2023

PACER
23

ATTORNEY Appearance for Defendants Chicago Police Department, City of Chicago by Elizabeth Ann Winkowski (Winkowski, Elizabeth) (Entered: 08/22/2023)

Aug. 22, 2023

Aug. 22, 2023

PACER
24

ATTORNEY Appearance for Defendants Chicago Police Department, City of Chicago by Thomas Hudson Cross, IV (Cross, Thomas) (Entered: 08/22/2023)

Aug. 22, 2023

Aug. 22, 2023

PACER
25

MOTION by Defendants Chicago Police Department, City of Chicago for extension of time to file answer regarding complaint 1 Defendant City of Chicago's Unopposed Motion for Extension of Time to Answer or Otherwise Plead (Sheehan, Michael) (Entered: 08/22/2023)

Aug. 22, 2023

Aug. 22, 2023

PACER
26

MINUTE entry before the Honorable Mary M. Rowland: Defendant City of Chicago's unopposed motion for extension of time to answer or otherwise plead 25 is granted. The time for Defendants to answer or otherwise plead in response to Plaintiffs' Complaint is extended to September 25, 2023. The time of 9/8/23 for parties to file a joint initial status report 10 is reset to 10/16/23. Mailed notice. (dm, ) (Entered: 08/23/2023)

Aug. 23, 2023

Aug. 23, 2023

PACER
27

MOTION by Defendants Chicago Police Department, City of Chicago for leave to file excess pages Defendants' Unopposed Motion to File a Brief in Excess of 15 Pages (Sheehan, Michael) (Entered: 09/19/2023)

Sept. 19, 2023

Sept. 19, 2023

PACER
28

MINUTE entry before the Honorable Mary M. Rowland: Defendants' unopposed motion to file a brief in excess of 15 pages 27 is granted. Defendants are granted leave to file a brief of up to 20 pages. Mailed notice. (dm, ) (Entered: 09/20/2023)

Sept. 20, 2023

Sept. 20, 2023

PACER
29

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants Chicago Police Department, City of Chicago Defendants' Motion to Dismiss Plaintiffs' Complaint Pursuant to Federal Rule of Civil Procedure 12(b)(6) (Sheehan, Michael) (Entered: 09/25/2023)

Sept. 25, 2023

Sept. 25, 2023

RECAP
30

MOTION by Defendants Chicago Police Department, City of Chicago to strike Certain Paragraphs from Complaint (Sheehan, Michael) (Entered: 09/25/2023)

Sept. 25, 2023

Sept. 25, 2023

RECAP
31

MINUTE entry before the Honorable Mary M. Rowland: Plaintiffs' response to Defendants' motion to dismiss 29 and motion to strike 30 due 10/24/23. Defendants' reply due 11/14/23. The court will rule by mail. Mailed notice. (dm, ) (Entered: 09/26/2023)

Sept. 26, 2023

Sept. 26, 2023

PACER
32

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-21180506. (Baskin, Cate) (Entered: 10/03/2023)

Oct. 3, 2023

Oct. 3, 2023

PACER
33

MINUTE entry before the Honorable Mary M. Rowland: Motion to appear pro hac vice by Cate Baskin 32 is granted. Counsel is reminded to become familiar with this court's local rules. Mailed notice. (dm, ) (Entered: 10/04/2023)

Oct. 4, 2023

Oct. 4, 2023

PACER
34

STATUS Report / JOINT INITIAL STATUS REPORT by Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins (Derocher, Patrick) (Entered: 10/16/2023)

Oct. 16, 2023

Oct. 16, 2023

PACER
35

MINUTE entry before the Honorable Mary M. Rowland: The court has reviewed the joint initial status report. In person status set for 10/25/23 at 9:00 AM. Out of town counsel may appear by Webex. Out of town counsel who wish to appear via WebEx should send one email to Courtroom Deputy Dawn Moreno at Dawn_Moreno@ilnd.uscourts.gov identifying the email addresses of the individuals who intend to participate in the video conference by 10/23/23. Counsel will receive an email with a link to join the video conference prior to the hearing. Members of the public and media will be able to call in to listen to this hearing. The call-in number is 650-479-3207 and the call-in ID is 1801732451. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice. (dm, ) (Entered: 10/18/2023)

Oct. 18, 2023

Oct. 18, 2023

PACER
36

MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins for extension of time to file response/reply as to motion to strike 30, Motion to Dismiss for Failure to State a Claim, 29 (Unopposed), MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins for leave to file excess pages (Unopposed) (Levin, Joshua) (Entered: 10/19/2023)

Oct. 19, 2023

Oct. 19, 2023

PACER
37

MINUTE entry before the Honorable Mary M. Rowland: Plaintiff's unopposed motion for extension of time and for leave to file brief in excess of 15 pages 36 is granted. The time for Plaintiffs to file their response briefs to Defendants' Motion to Dismiss and Motion to Strike is extended to November 14, 2023. Plaintiffs are granted leave to file a brief of up to 20 pages. Defendants' reply is extended to 12/5/23. The court will rule by mail. Mailed notice. (dm, ) (Entered: 10/20/2023)

Oct. 20, 2023

Oct. 20, 2023

PACER
38

MINUTE entry before the Honorable Mary M. Rowland: In person status hearing held. Plaintiff reported on data reporting records from 2016. Rule 26(a)(1) disclosures due November 30, 2023; parties to issue first set of discovery requests by December 7, 2023. Fact discovery to close on 1/31/25. This is 14 months to conduct discovery. The Court does not anticipate extending this deadline. Expert discovery schedule will be set later. In person status set for 1/25/24 at 9:30am. Mailed notice. (dm, ) (Entered: 10/25/2023)

Oct. 25, 2023

Oct. 25, 2023

PACER
39

RESPONSE by Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkinsin Opposition to MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants Chicago Police Department, City of Chicago Defendants' Motion to Dismiss Plaintiffs' Complaint Pursuant to Federal Rule of Civil Procedure 12(b)(6) 29 (Levin, Joshua) (Entered: 11/14/2023)

Nov. 14, 2023

Nov. 14, 2023

RECAP
40

RESPONSE by Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkinsin Opposition to MOTION by Defendants Chicago Police Department, City of Chicago to strike Certain Paragraphs from Complaint 30 (Levin, Joshua) (Entered: 11/14/2023)

Nov. 14, 2023

Nov. 14, 2023

RECAP
41

MOTION by Defendants Chicago Police Department, City of Chicago for extension of time to file response/reply as to motion to strike 30, Motion to Dismiss for Failure to State a Claim, 29 *UNOPPOSED* (Winkowski, Elizabeth) (Entered: 11/27/2023)

Nov. 27, 2023

Nov. 27, 2023

PACER
42

MINUTE entry before the Honorable Mary M. Rowland: Defendants' unopposed motion for extension of time to file reply briefs to their motion to dismiss and motion to strike 41 is granted. The time for Defendants to file reply briefs to their Motion to Dismiss and Motion to Strike until is extended to December 12, 2023. Mailed notice. (dm, ) (Entered: 11/28/2023)

Nov. 28, 2023

Nov. 28, 2023

PACER
43

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-21377179. (Menjivar, Stacey) (Entered: 11/30/2023)

Nov. 30, 2023

Nov. 30, 2023

PACER
44

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-21377548. (Skaroff, Mikaila) (Entered: 11/30/2023)

Nov. 30, 2023

Nov. 30, 2023

PACER
45

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-21379131. (Hannemann, Andrew) (Entered: 11/30/2023)

Nov. 30, 2023

Nov. 30, 2023

PACER
46

MINUTE entry before the Honorable Mary M. Rowland: Motions to appear pro hac vice by Stacey Menjivar 43, Mikaila Skaroff 44, and Andrew Hannemann 45 are granted. Counsel is reminded to become familiar with this court's local rules. Mailed notice. (dm, ) (Entered: 12/01/2023)

Dec. 1, 2023

Dec. 1, 2023

PACER
47

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by Mikaila Skaroff (Skaroff, Mikaila) (Entered: 12/07/2023)

Dec. 7, 2023

Dec. 7, 2023

PACER
48

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by Andrew Hannemann (Hannemann, Andrew) (Entered: 12/07/2023)

Dec. 7, 2023

Dec. 7, 2023

PACER
49

ATTORNEY Appearance for Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins by Stacey Menjivar (Menjivar, Stacey) (Entered: 12/07/2023)

Dec. 7, 2023

Dec. 7, 2023

PACER
50

REPLY by Defendants Chicago Police Department, City of Chicago to motion to strike 30 Defendants' Reply in Support of Their Motion to Strike Certain Paragraphs from Complaint (Attachments: # 1 Exhibit A - DKT 33 - Cosby Transcript)(Sheehan, Michael) (Entered: 12/12/2023)

Dec. 12, 2023

Dec. 12, 2023

PACER
51

REPLY by Defendants Chicago Police Department, City of Chicago to Motion to Dismiss for Failure to State a Claim, 29 Defendants' Reply in Support of their Motion to Dismiss Plaintiffs' Complaint Pursuant to Federal Rule of Civil Procedure 12(b)(6) (Sheehan, Michael) (Entered: 12/12/2023)

Dec. 12, 2023

Dec. 12, 2023

RECAP
52

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/28/2023: Mailed notice. (tg, ) (Entered: 12/28/2023)

Dec. 28, 2023

Dec. 28, 2023

PACER
53

AFFIDAVIT of Service filed by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins regarding Subpoena served on Keeper of Records, Illinois State Police on 12/29/2023 (Block, Alexandra) (Entered: 01/09/2024)

Jan. 9, 2024

Jan. 9, 2024

RECAP
54

MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins for protective order (Attachments: # 1 Exhibit Propsed Confidentiality Order)(Block, Alexandra) (Entered: 01/23/2024)

Jan. 23, 2024

Jan. 23, 2024

RECAP
55

MINUTE entry before the Honorable Mary M. Rowland: In person status and motion hearing held. Both parties have issued discovery. Parties agreed to a rolling production start date of 2/7/24. The court adopts paragraph 2 of the model protective order submitted by Plaintiff. Parties are to meet and confer regarding paragraphs 3 and 7 and resubmit a proposed protective order for entry by 1/29/24. Any motion regarding ESI protocol or an agreed ESI protocol due 2/8/24. Mailed notice. (dm, ) (Entered: 01/25/2024)

Jan. 25, 2024

Jan. 25, 2024

PACER
56

MINUTE entry before the Honorable Mary M. Rowland: Plaintiffs' motion for entry of confidentiality order 54 is granted. Enter Confidentiality Protective Order. Mailed notice. (dm, ) (Entered: 01/29/2024)

Jan. 29, 2024

Jan. 29, 2024

PACER
57

CONFIDENTIALITY PROTECTIVE ORDER Signed by the Honorable Mary M. Rowland on 1/29/2024. Mailed notice. (dm, ) (Entered: 01/29/2024)

Jan. 29, 2024

Jan. 29, 2024

PACER
58

MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins/ JOINT MOTION FOR ENTRY OF ESI PROTOCOL AND STATUS CONFERENCE (Derocher, Patrick) (Entered: 02/08/2024)

Feb. 8, 2024

Feb. 8, 2024

PACER
59

MINUTE entry before the Honorable Mary M. Rowland: The Court has reviewed the parties' joint motion for entry of ESI protocol 58 . ESI Stipulation Entered. The Court sets a status hearing for 4/2/24 at 9:30 am. Mailed notice. (dm, ) (Entered: 02/09/2024)

Feb. 9, 2024

Feb. 9, 2024

PACER
60

JOINT STIPULATION AND ORDER ON ELECTRONICALLY STORED INFORMATION AND INADVERTENT DISCLOSURES Signed by the Honorable Mary M. Rowland on 2/9/2024. Mailed notice. (dm, ) (Entered: 02/09/2024)

Feb. 9, 2024

Feb. 9, 2024

PACER
61

AFFIDAVIT of Service filed by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins regarding Subpoena served on Keeper of Records, Illinois Secretary of State on 2/2/2024 (Block, Alexandra) (Entered: 02/12/2024)

Feb. 12, 2024

Feb. 12, 2024

PACER
62

MINUTE entry before the Honorable Mary M. Rowland: On the court's own motion, status hearing set for 4/2/24 is reset to 9:00 AM. (Please Note Time Change Only) Mailed notice. (dm, ) (Entered: 03/11/2024)

March 11, 2024

March 11, 2024

PACER
63

AFFIDAVIT of Service filed by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins regarding Subpoena served on Keeper of Records, Illinois Department of Transportation on 03/04/2024 (Block, Alexandra) (Entered: 03/12/2024)

March 12, 2024

March 12, 2024

PACER
64

ATTORNEY Appearance for Defendants Chicago Police Department, City of Chicago by Sara J Schroeder (Schroeder, Sara) (Entered: 03/22/2024)

March 22, 2024

March 22, 2024

PACER
65

ATTORNEY Appearance for Defendants Chicago Police Department, City of Chicago by Barton James O'Brien (O'Brien, Barton) (Entered: 03/22/2024)

March 22, 2024

March 22, 2024

PACER
66

MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins to compel (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F)(Block, Alexandra) (Entered: 03/27/2024)

1 Exhibit A

View on PACER

2 Exhibit B

View on PACER

3 Exhibit C

View on PACER

4 Exhibit D

View on PACER

5 Exhibit E

View on PACER

6 Exhibit F

View on PACER

March 27, 2024

March 27, 2024

PACER
67

RESPONSE by Chicago Police Department, City of Chicagoin Opposition to MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins to compel 66 Defendants' Response in Opposition to Plaintiffs' Motion to Compel (Sheehan, Michael) (Entered: 04/01/2024)

April 1, 2024

April 1, 2024

PACER
68

TRANSCRIPT OF PROCEEDINGS held on 4/2/24 before the Honorable Mary M. Rowland. Status/motion hearing. Order Number: 48395. Court Reporter Contact Information: Laura Renke, OfficialTranscript@gmail.com, 312.435.6053. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 4/23/2024. Redacted Transcript Deadline set for 5/3/2024. Release of Transcript Restriction set for 7/1/2024. (Renke, Laura) (Entered: 04/02/2024)

April 2, 2024

April 2, 2024

PACER
69

MINUTE entry before the Honorable Mary M. Rowland: In person status and motion hearing held. The court heard argument on Plaintiffs' motion to compel 66 . For the reasons stated on the record, Plaintiffs' motion to compel is taken under advisement. Status hearing set for 5/21/24 at 9:30am. Mailed notice. (dm, ) (Entered: 04/03/2024)

April 2, 2024

April 2, 2024

PACER
70

MINUTE entry before the Honorable Mary M. Rowland: The status hearing set for 5/21/2024 is stricken and reset to 6/13/2024 at 9:30 a.m. Mailed notice (ags) (Entered: 05/16/2024)

May 16, 2024

May 16, 2024

PACER
71

MINUTE entry before the Honorable Mary M. Rowland: The Court, upon request from both parties, strikes the status hearing set for 6/13/24 and resets to 6/18/2024 at 9:00 a.m. Mailed notice (ags) (Entered: 05/16/2024)

May 16, 2024

May 16, 2024

PACER
72

MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins to compel (Attachments: # 1 Exhibit Exhibits A-L)(Block, Alexandra) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
73

MOTION by Attorney CATE BASKIN to withdraw as attorney for Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins. No party information provided (Derocher, Patrick) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
74

MINUTE entry before the Honorable Mary M. Rowland: Plaintiffs' motion to compel 72 will be heard on 6/18/24 at 9:00 a.m. Mailed notice. (dm, ) (Entered: 05/28/2024)

May 28, 2024

May 28, 2024

PACER
75

MINUTE entry before the Honorable Mary M. Rowland: Plaintiffs' motion for leave to withdraw Cate Baskin as counsel for plaintiffs 73 is granted. Attorney Baskin is terminated as counsel of record. Mailed notice. (dm, ) (Entered: 05/28/2024)

May 28, 2024

May 28, 2024

PACER
76

MEMORANDUM Opinion and Order: The City's motion to dismiss 29 is granted in part and denied in part. Count I (Equal Protection claim under the Fourteenth Amendment) and Count IV (ICRA claim) may proceed. Count III (Illinois Constitution claim) is voluntarily dismissed. Count II (Title VI claim) is dismissed. The City's motion to strike 30 is denied. Plaintiffs are directed to file an amended complaint by June 17, 2024. The City is directed to answer the amended complaint by June 28, 2024. Signed by the Honorable Mary M. Rowland on 6/10/2024. (See attached Order for further detail.) Mailed notice. (dm, )

June 10, 2024

June 10, 2024

Clearinghouse
77

RESPONSE by Chicago Police Department, City of Chicagoin Opposition to MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins to compel 72 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Sheehan, Michael) (Entered: 06/13/2024)

June 13, 2024

June 13, 2024

PACER
78

MINUTE entry before the Honorable Mary M. Rowland: The court resets the hearing from 6/18/24 at 9:00 to 6/26/24 at 2:00 PM. Mailed notice. (dm, ) (Entered: 06/14/2024)

June 14, 2024

June 14, 2024

PACER
79

MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins for extension of time to file Amended Complaint (Derocher, Patrick) (Entered: 06/14/2024)

June 14, 2024

June 14, 2024

PACER
80

MINUTE entry before the Honorable Mary M. Rowland: Plaintiffs' unopposed motion for extension of time to file amended complaint 79 is granted. Plaintiffs shall file their amended complaint by 7/2/24. Defendants shall answer or otherwise respond to Plaintiffs' amended complaint by 7/19/24. Mailed notice. (dm, ) (Entered: 06/17/2024)

June 17, 2024

June 17, 2024

PACER
81

MOTION by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins to compel (Block, Alexandra) (Entered: 06/21/2024)

June 21, 2024

June 21, 2024

PACER
82

REPLY by Plaintiffs Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins to motion to compel 72 (Block, Alexandra) (Entered: 06/21/2024)

June 21, 2024

June 21, 2024

PACER
83

MOTION by Defendant City of Chicago to stay Defendant City of Chicago 's Motion to Stay Proceedings (Sheehan, Michael) (Entered: 06/24/2024)

June 24, 2024

June 24, 2024

PACER
84

MINUTE entry before the Honorable Mary M. Rowland: In person motion hearing held. The court heard argument on Defendants' motion to stay 83 . For the reasons stated on the record, Defendant's motion is denied. Ruling on motions to compel [66, 72] is set for 8/7/24 at 9:00am. Motion at Dkt. 81 is terminated as it was incorrectly filed as a motion. Mailed notice. (dm, ) (Entered: 06/26/2024)

June 26, 2024

June 26, 2024

PACER
85

TRANSCRIPT OF PROCEEDINGS held on 6/26/24 before the Honorable Mary M. Rowland. Motion hearing. Order Number: 49160. Court Reporter Contact Information: Laura Renke, OfficialTranscript@gmail.com, 312.435.6053. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 7/18/2024. Redacted Transcript Deadline set for 7/29/2024. Release of Transcript Restriction set for 9/25/2024. (Renke, Laura) (Entered: 06/27/2024)

June 27, 2024

June 27, 2024

PACER
86

ATTORNEY Appearance for Defendants Chicago Police Department, City of Chicago by Joan E Ahn (Ahn, Joan) (Entered: 06/27/2024)

June 27, 2024

June 27, 2024

PACER
87

First Class Action AMENDED complaint by Eric Wilkins, Jose Manuel Almanza, Jr., Essence Jefferson, Mahari Bell, Jacquez Beasley against All Defendants (Block, Alexandra) (Entered: 07/02/2024)

July 2, 2024

July 2, 2024

Clearinghouse
88

MOTION by Defendant City of Chicago for extension of time to file answer regarding amended complaint 87 (Attachments: # 1 Exhibit A)(Sheehan, Michael) (Entered: 07/18/2024)

July 18, 2024

July 18, 2024

PACER
89

RESPONSE by Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkinsin Opposition to MOTION by Defendant City of Chicago for extension of time to file answer regarding amended complaint 87 88 (Block, Alexandra) (Entered: 07/19/2024)

July 19, 2024

July 19, 2024

PACER
90

MINUTE entry before the Honorable Mary M. Rowland: In light of the Democratic National Convention and the demand on the City's resources, the Court grants the motion for extension of time. 88 . The City's Answer to the amended complaint is due 9/20/24. Discovery is to continue in the interim. Mailed notice. (dm, ) (Entered: 07/22/2024)

July 22, 2024

July 22, 2024

PACER
91

MINUTE entry before the Honorable Mary M. Rowland: Hearing held on Plaintiffs' second motion to compel ESI 72 . The Court ruled as follows: the court adopts the City's proposed custodians except enlarges it to include the leadership personnel for the Traffic Unit and the personnel involved in the traffic stops of the incidents alleged in the Amended Complaint. Defendants are to provide a list of custodians including the traffic unit to Plaintiffs by 8/30/24. The Court adopts the defendants ESI sources 77 at 7, in addition the City agreed to search the shared drives of all the Units being searched, including the Mayor's office, command staff, Patrol Chief, summer mobile unit and community safety team. The Court denies the motion as to personal devices for mayors and deputy mayors. The Court incorporates the terms proposed by the Plaintiffs (In addition to those proposed by the City) except for the term "traffic". Plaintiffs' terms are to be coupled with "traffic stop" to limit the number of hits. Defendants are ordered to run search terms as modified and produce the number of hits to Plaintiffs by 9/20/24. ESI data for above rank commander will begin from 10/1/2015 and ESI data from everyone below commander will begin from 1/1/2016. Parties are to file a status report by 9/27/24. Status hearing set for 10/9/24 at 9:00am. Mailed notice. (dm, ) (Entered: 08/09/2024)

Aug. 7, 2024

Aug. 7, 2024

RECAP
92

MOTION by Attorney Joshua Levin to withdraw as attorney for Jose Manuel Almanza, Jr., Jacquez Beasley, Mahari Bell, Essence Jefferson, Eric Wilkins. No party information provided (Levin, Joshua) (Entered: 08/16/2024)

Aug. 16, 2024

Aug. 16, 2024

RECAP
93

MINUTE entry before the Honorable Mary M. Rowland: Attorney Joshua Levin's motion for leave to withdraw appearance 92 is granted. Attorney Levin terminated as counsel of record for plaintiffs. Mailed notice. (dm, ) (Entered: 08/19/2024)

Aug. 19, 2024

Aug. 19, 2024

PACER
94

TRANSCRIPT OF PROCEEDINGS held on 8/7/24 before the Honorable Mary M. Rowland. Order Number: 49499. Court Reporter Contact Information: Joseph Rickhoff, 312-435-5562, joseph_rickhoff@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 9/16/2024. Redacted Transcript Deadline set for 9/24/2024. Release of Transcript Restriction set for 11/22/2024. (Rickhoff, Joseph) (Entered: 08/24/2024)

Aug. 24, 2024

Aug. 24, 2024

PACER
95

MOTION by Defendant City of Chicago for extension of time to Produce Number of Hits for Certain ESI Sources (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Sheehan, Michael) (Entered: 09/20/2024)

Sept. 20, 2024

Sept. 20, 2024

PACER
96

ANSWER to amended complaint and Affirmative Defenses by City of Chicago(Sheehan, Michael) (Entered: 09/20/2024)

Sept. 20, 2024

Sept. 20, 2024

Clearinghouse

Case Details

State / Territory: Illinois

Case Type(s):

Policing

Special Collection(s):

Traffic Stop Litigation

Key Dates

Filing Date: June 26, 2023

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

Five plaintiffs who had been repeatedly stopped by CPD officers, on behalf of a putative class of black and Latino people subject to traffic stops by CPD.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

ACLU Affiliates (any)

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Pending

Defendants

City of Chicago, City

Chicago Police Department, City

Defendant Type(s):

Law-enforcement

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

State law

Title VI, Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.

State Anti-Discrimination Law

Ex parte Young (federal or state officials)

Constitutional Clause(s):

Equal Protection

Available Documents:

Trial Court Docket

Complaint (any)

Any published opinion

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None yet

Source of Relief:

None yet

Issues

General/Misc.:

Failure to discipline

Failure to supervise

Failure to train

Pattern or Practice

Racial profiling

Search policies

Staff (number, training, qualifications, wages)

Discrimination Area:

Disparate Treatment

Discrimination Basis:

National origin discrimination

Race discrimination

Affected National Origin/Ethnicity(s):

Hispanic

Affected Race(s):

Black

Policing:

Traffic Stops