Ronald Crosby v. City of Chicago

Summary

The Seventh Circuit held that a broad release in a settlement agreement covering all claims "arising directly or indirectly out of the incident" barred subsequent claims for coverup, malicious prosecution, and wrongful conviction, even if those claims had not yet accrued. Applying Illinois law and following *Cannon v. Burge*, the court rejected arguments that the release was limited to the specific claims in the original suit or that the coverup was a separate incident. The court also affirmed the district court's award of costs for transcripts under Rule 54(d).

Holdings

1. The release bars Crosby's new claims because they arise from the same incident, and Illinois law enforces the release as written where the claims were foreseeable.
2. The district court did not abuse its discretion because the City reasonably incurred costs for transcripts of Crosby's state criminal proceedings, which were relevant to the litigation.

Questions Presented

1. Whether the settlement agreement's release of all claims arising directly or indirectly from the incident bars Crosby's new claims for coverup and malicious prosecution.
2. Whether the district court abused its discretion in awarding costs to the City for transcripts of Crosby's state criminal proceedings.

Disposition

affirmed