Benedix v. VILLAGE OF HANOVER PARK, ILL., 677 F.3d 317

Benedix, Executive Coordinator to the Village Manager, was treated as a staff member of Village Manager Hummel who was ousted in a political shift.
The Village restructured its workforce by abolishing three positions and creating one new slot, affecting Benedix’s position.
Benedix sued under 42 U.S.C. § 1983 claiming her association with Hummel violated her First Amendment rights.
The district court dismissed on legislative immunity grounds, treating the ordinance as protection for the officials who adopted it.
The Seventh Circuit held that while the ordinance is protected by legislative immunity for the officials, the Village itself remains a defendant under Monell for its official policy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ordinance eliminating Benedix's position is shielded by legislative immunity.	Benedix contends the ordinance targeted her and thus should not be protected as mere legislation.	Defendants argue the ordinance was adopted through the legislative process and is insulated by legislative immunity.	Legislative immunity covers the ordinance's enactment.

Tenney v. Brandhove, 341 U.S. 367 (1951) (legislative immunity for official acts)
Rateree v. Rockett, 852 F.2d 946 (7th Cir. 1988) (governmental immunity principles in public employment)
Monell v. New York City Dep't of Social Services, 436 U.S. 658 (1978) (municipal liability for official policy under §1983)
Owen v. Independence, 445 U.S. 622 (1980) (no immunity for municipalities from §1983 damages)
Hurley v. Irish-Am. Gay, Lesbian & Bisexual Group of Boston, 515 U.S. 557 (1995) (organization rights and expressive association in public actions)