Michael Moore v. Thomas Dart, et al.

Summary

The United States District Court for the Northern District of Illinois dismissed Michael Moore’s First Amendment retaliation claim against Cook County Sheriff Thomas Dart in his individual capacity. The court held that the complaint did not plausibly allege Dart’s personal involvement in the disciplinary charges that led to Moore’s termination. The court declined supplemental jurisdiction over the remaining state-law claims, dismissing them without prejudice and denying the Merit Board’s motion to dismiss as moot.

Holdings

1. A government official is not personally liable under § 1983 merely because the official heads an organization or is named in a signature block; the complaint must plausibly allege that the official personally caused or participated in the constitutional deprivation.
2. After dismissing all claims within its original jurisdiction before trial, the court may decline supplemental jurisdiction over the remaining state-law claims and ordinarily should dismiss those claims without prejudice.

Questions Presented

1. Whether Moore adequately pleaded Sheriff Dart's personal involvement in the alleged First Amendment retaliation claim against Dart in his individual capacity.
2. Whether the court should exercise supplemental jurisdiction over the remaining state-law claims after dismissing the only federal claim.

Disposition

dismissed