Gregory Ivory Stamps v. Thomas J. Dart, Priscilla Ware, Kevin Kuca, Thomas Hogan, Velinda Llorens, and Cook County, Illinois

Summary

The United States District Court for the Northern District of Illinois granted Defendants’ motion to dismiss Gregory Stamps’s claims arising from alleged deliberate indifference to a serious medical condition and related Monell liability. The court held that the claims against the individual defendants were barred by Illinois’s two-year statute of limitations because the amended complaints did not relate back and equitable tolling did not apply. The court also dismissed the Monell claim because there was no viable underlying constitutional violation.

Holdings

1. The deliberate-indifference claims accrued on January 4, 2023 and were subject to Illinois's two-year statute of limitations, which expired on January 4, 2025. Because Stamps did not name Kuca, Hogan, or Llorens until June 2025, the claims were untimely unless preserved by relation back or equitable tolling.
2. The amended complaints did not relate back to the original complaint under the applicable federal or Illinois relation-back standards because identifying previously unknown John Doe defendants is not a qualifying mistake concerning the proper party's identity.
3. Equitable tolling did not apply because Stamps failed to show that she could not learn the defendants' identities through due diligence.
4. The Monell claim was properly dismissed because, after dismissal of the time-barred claims against Kuca, Hogan, and Llorens, Stamps could not establish an underlying constitutional violation by a municipal employee.

Questions Presented

1. Whether Stamps's deliberate-indifference claims against Kuca, Hogan, and Llorens were barred by Illinois's two-year statute of limitations.
2. Whether the amended complaint naming the previously unknown defendants related back to the original complaint under Federal Rule of Civil Procedure 15(c)(1)(A), Illinois Code of Civil Procedure § 2-616(d), or Federal Rule of Civil Procedure 15(c)(1)(C).
3. Whether equitable tolling preserved Stamps's untimely deliberate-indifference claims.
4. Whether Stamps stated a Monell claim against Dart, Ware, and Cook County when the underlying employee claims were dismissed as time barred.

Disposition

dismissed