Robinson v. Village of Sauk Village, 201 N.E.3d 1091

Early-morning police pursuit of a reported stolen Buick driven by Mark Coffey reached a church parking lot in Dyer, Indiana; officers confronted Coffey with weapons drawn and ordered him to show his hands.
Coffey remained in the running vehicle, ignored commands, then drove away and led officers on a high-speed chase through multiple jurisdictions.
During the chase Coffey struck Javier Robinson in a crosswalk, causing severe injuries; Coffey later was shot and killed by Indiana officers.
Plaintiff sued the officers and their municipalities for willful and wanton conduct; defendants moved for summary judgment asserting absolute immunity under § 4-106(b) of the Tort Immunity Act (immunity for injury inflicted by an "escaped or escaping prisoner").
The trial court granted summary judgment for defendants, finding Coffey was in custody when confronted in the parking lot. The appellate court reversed, concluding Coffey was not an "escaped or escaping prisoner."
The Illinois Supreme Court affirmed the appellate court: custody under § 4-106(b) requires direct physical control or limitation of movement, and a mere show of authority is insufficient to trigger absolute immunity; case remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 4-106(b) immunity applies because the driver was an "escaped or escaping prisoner"	A show of authority (guns drawn, commands) is not custody; Coffey was free to leave	Officers' show of authority and presence of multiple units effectively held Coffey in custody	Held: custody requires direct physical control/limitation of movement; show of authority alone insufficient, so § 4-106(b) immunity does not apply

Ries v. City of Chicago, 242 Ill. 2d 205 (2011) (interprets § 4-106(b); emphasizes that being "held in custody" requires direct control limiting freedom of movement)
People v. Campa, 217 Ill. 2d 243 (2005) (discusses the elasticity of the term 'custody' and cites dictionary definitions)
Brendlin v. California, 551 U.S. 249 (2007) (during a traffic stop an officer seizes vehicle occupants)
Miranda v. Arizona, 384 U.S. 436 (1966) (defines custodial interrogation concept used for context on 'custody')