Girard v. Village of Glencoe, Illinois
1:24-cv-06882
N.D. Ill.Aug 12, 2025Background
- Plaintiffs Kenton Girard and his minor children, Gw. and Gr., brought a federal lawsuit arising out of a contentious ongoing state court custody dispute in Cook County, Illinois.
- Plaintiffs alleged a widespread conspiracy involving bribery and corruption among attorneys at Beermann LLP (representing Jane Girard), two state court judges (Boyd and Goldfarb), court-appointed therapists, a police detective, and a DCFS worker, all aimed at influencing the custody proceedings and covering up alleged child sexual assault.
- Gr. and Gw.'s claims were dismissed without prejudice because their attorney was not properly admitted to practice before the court, and minors cannot proceed pro se or via a non-admitted attorney.
- Kenton's claims against the state court judges (Boyd and Goldfarb) were dismissed with prejudice on judicial immunity grounds as their orders were judicial acts within their jurisdiction.
- The federal court abstained from hearing Kenton's civil RICO and related claims against the Beermann Defendants, finding federal intervention would improperly disrupt the pending state proceedings; these claims were dismissed without prejudice.
- The court declined supplemental jurisdiction over remaining state law claims against other defendants, dismissing them without prejudice, and terminated the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial Immunity for State Judges | Judges accepted bribes and issued biased rulings | Judges acted within judicial capacity; immunity applies | Judicial immunity bars claims; dismissed with prejudice |
| Federal Jurisdiction over RICO Claims | Federal court should address alleged Beermann corruption | Claims would disrupt state custody case; abstention required | Abstention warranted; claims dismissed without prejudice |
| Representation of Minor Children | Gr. and Gw. represented by (non-admitted) attorney | Attorney not authorized to appear; minors cannot proceed pro se | Minors’ claims dismissed without prejudice |
| Retention of State Law Claims | Sought to proceed on state law negligence, conspiracy claims | No federal claims remain; court should decline jurisdiction | Court declines supplemental jurisdiction; dismissed |
Key Cases Cited
- Stump v. Sparkman, 435 U.S. 349 (judges are absolutely immune for judicial acts unless taken in complete absence of jurisdiction)
- Bonte v. U.S. Bank, N.A., 624 F.3d 461 (failure to respond to dismissal arguments may constitute waiver)
- J.B. v. Woodard, 997 F.3d 714 (abstention may be appropriate to avoid interfering with ongoing state family law proceedings)
- Davis v. Cook Cnty., 534 F.3d 650 (federal courts should generally decline supplemental jurisdiction when all federal claims have been dismissed)