Douglas Johnson v. Cook County Sheriff Thomas Dart, in his official capacity, Antwaun Bacon, and Cook County

Summary

The court denied summary judgment motions concerning claims arising from the allegedly excessively tight handcuffing of pretrial detainee Douglas Johnson during transport within the Cook County Department of Corrections. The court held that genuine disputes of material fact existed regarding excessive force, qualified immunity, and whether Johnson was denied the benefit of a family visit because of his disability. The court also denied Johnson’s motion to strike, granted his request to voluntarily dismiss the Monell claim against Sheriff Dart with prejudice, and set a telephonic hearing.

Holdings

1. Summary judgment was denied because disputed facts could allow a reasonable jury to find that Officer Bacon's use of handcuffs, particularly allegedly excessive tightening and refusal to loosen them after Johnson reported pain, was objectively unreasonable.
2. Officer Bacon was not entitled to qualified immunity at summary judgment.
3. Summary judgment was denied on Johnson's Rehabilitation Act and ADA claims because a reasonable jury could find that he was denied the benefit of a family visit by being required to access it while suffering severe pain.
4. Plaintiff's motion to strike was denied, although the court declined to give weight to defendants' vicarious-liability argument because it was raised for the first time in reply.
5. Johnson's Monell claim against Sheriff Dart was voluntarily dismissed with prejudice.

Questions Presented

1. Whether genuine disputes of material fact precluded summary judgment on Johnson's Fourteenth Amendment excessive-force claim based on forcing him to walk a long distance while handcuffed and allegedly tightening the handcuffs excessively.
2. Whether Officer Bacon was entitled to qualified immunity on the excessive-force claim.
3. Whether genuine disputes of material fact precluded summary judgment on Johnson's Rehabilitation Act and ADA claims based on allegedly denying him the benefit of a family visit by requiring him to access it in severe pain.
4. Whether defendants' vicarious-liability argument was properly raised for the first time in a reply brief.
5. Whether Johnson's Monell claim should be voluntarily dismissed with prejudice.

Disposition

other