Armani Bell v. City of Chicago, 694 F. App'x 408

Armani Bell was charged with murder in January 2011 after a drug deal resulted in John Lemon’s death; he was acquitted in February 2014 and sued the City of Chicago, two officers (Reiff and Stanek), the CPD superintendent, and the Fraternal Order of Police (FOP).
Bell alleged constitutional violations (due process, equal protection) under 42 U.S.C. § 1983, a § 1985 conspiracy, civil conspiracy, and malicious prosecution; he later added claims that officers beat/tortured him and that the FOP’s collective bargaining agreement conferred unlawful preferential treatment.
The district court dismissed Bell’s first amended complaint for failure to state a claim, allowed a second amended complaint (SAC), then dismissed the SAC with prejudice as time-barred under the two-year statute of limitations for federal claims and dismissed state claims without prejudice.
The district court also denied Bell leave to amend further, denied his emergency discovery/preservation motion as moot, and sanctioned Bell’s attorney (Lawrence Redmond) for filing a legally frivolous equal protection claim against the FOP.
On appeal Bell challenged the sanctions, the dismissal with prejudice, the denial of leave to amend, and the denial of emergency discovery; the Seventh Circuit affirmed in all respects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sanctions order is appealable and proper	Sanctions appeal should be dismissed because attorney wasn’t named on the notice of appeal	District court plainly sanctioned counsel (Redmond); appealable and supported by Rule 11 standards	Sanctions appeal is proper; district court did not abuse discretion in sanctioning counsel for a frivolous claim
Whether federal claims were timely (statute of limitations)	Claims should not be time-barred; sought leave to amend to cure deficiencies	Federal claims accrued at arrest/charge in Jan 2011 and are barred by two-year statute; suit filed Aug 2014	Federal claims are time-barred; dismissal with prejudice affirmed
Whether denial of leave to amend was an abuse of discretion	District court should have reviewed Bell’s proposed third amended complaint before dismissal	Proposed amendment would not cure the accrual/time-bar issue; futility justified denial	Denial of leave to amend not an abuse of discretion because amendment could not overcome the statute-of-limitations bar
Whether emergency discovery/preservation relief was wrongly denied	Preservation of disciplinary records is necessary for current/future claims; arbitration order threatened destruction	Records for involved officers already preserved; case dismissal renders discovery moot	Denial not an abuse of discretion; discovery/preservation requests are moot after dismissal

Foreman v. Wadsworth, 844 F.3d 620 (7th Cir. 2016) (notice-of-appeal formality does not defeat appeal when the appealing party’s identity and intent are clear)
Mars Steel Corp. v. Cont'l Bank N.A., 880 F.2d 928 (7th Cir. 1989) (Rule 11 does not chill reasonable legal evolution but forbids claims lacking any legal support)
Vesely v. Armslist LLC, 762 F.3d 661 (7th Cir. 2014) (standard of review for Rule 12(b)(6) motions)
Wallace v. Kato, 549 U.S. 384 (2007) (accrual rule for § 1983 claims tied to events that injure plaintiff, such as arrest/charge)
Rosado v. Gonzalez, 832 F.3d 714 (7th Cir. 2016) (application of accrual principles to § 1983 claims)
Groce v. Eli Lilly & Co., 193 F.3d 496 (7th Cir. 1999) (dismissal of state supplemental claims without prejudice when all federal claims are dismissed)
Mulvania v. Sheriff of Rock Island Cty., 850 F.3d 849 (7th Cir. 2017) (abuse-of-discretion standard for denial of leave to amend)
Gonzalez-Koeneke v. West, 791 F.3d 801 (7th Cir. 2015) (denial of leave to amend appropriate when amendment would not cure fatal defects)
Packman v. Chicago Tribune Co., 267 F.3d 628 (7th Cir. 2001) (standard of review for discovery rulings)

We AFFIRM.