442 F.Supp.3d 1031
N.D. Ill.2020Background
- Percy R. Taylor was a Cook County Sheriff’s Office employee (Deputy in 1995; promoted to Police Officer in 2000); he faced a Loudermill hearing on March 22, 2011 and was later suspended and then terminated by the Merit Board on October 30, 2013.
- Taylor filed administrative and state-court challenges; the Cook County Circuit Court vacated the Merit Board’s 2013 termination as improperly constituted and remanded the matter to the Merit Board; the appellate court affirmed and the Illinois Supreme Court denied review.
- The state court ordered the Merit Board to take additional evidence and determine back pay; on August 15, 2019 the Circuit Court held Taylor’s termination was illegal and that he was entitled to backpay (the sole remaining issue was amount).
- In federal court Taylor sued under 42 U.S.C. § 1983 and Title VII (and asserted state-law claims) and moved for partial summary judgment seeking an order requiring reinstatement to the Sheriff’s payroll and award of backpay (over $500,000).
- Defendants argued the requested relief was premature, barred by Rooker–Feldman, and beyond the court’s authority under Illinois’s Administrative Review Law (ARL); the district court denied Taylor’s partial summary judgment motion and declined to grant the requested payroll/backpay relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authority to order reinstatement and backpay in this federal case | Taylor: no genuine dispute; court should order immediate reinstatement and backpay | Defs: state-court remand and ARL control; federal court lacks authority; relief premature | Denied — federal court lacks authority to grant requested reinstatement/backpay given state-court proceedings and remand |
| Whether the requested relief is barred by Rooker–Feldman / mootness | Taylor: entitlement to backpay is independent of federal claims | Defs: federal relief would improperly supplant state-court review; Rooker–Feldman/mootness apply | Court treated state-court remand as dispositive; cannot adjudicate the state court’s decision here |
| Whether ARL prevents district court from deciding backpay/reinstatement | Taylor: entitlement not contingent on prevailing in administrative proceedings | Defs: ARL vests jurisdiction in state court that first acquired review; federal court cannot substitute its remedy | Court concluded ARL/state-court remand foreclose district-court relief on those remedies |
| Motion to strike defendants’ supplemental statement | Taylor: objected to late supplement | Defs: submitted supplementary facts | Court did not rely on supplement; motion to strike denied as moot |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
- Anderson v. Liberty Lobby, 477 U.S. 242 (genuine-dispute standard for summary judgment)
- Skiba v. Ill. Cent. R.R. Co., 884 F.3d 708 (7th Cir. 2018) (view evidence in favor of nonmovant and draw reasonable inferences)
- White v. City of Chicago, 829 F.3d 837 (7th Cir. 2016) (distinguishing reasonable from speculative inferences at summary judgment)
- Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532 (due-process right to a pretermination hearing)
- Campos v. Cook County, 932 F.3d 972 (7th Cir. 2019) (district court cannot order reinstatement/backpay where state court has remanded to Merit Board)