United States District Court, N.D. Illinois, Eastern Division
Sylvia Mathlock, as mother and next friend of J.R., a minor, Plaintiff,
Eric Fleming, Najuan Mack, Leonard Dixon, Office of the Chief Judge of the Circuit Court of Cook County, and County of Cook, Illinois, Defendants.
MEMORANDUM OPINION AND ORDER
S. SHAH UNITED STATES DISTRICT JUDGE
J.R. (a minor) was detained at the Cook County Juvenile
Temporary Detention Center, defendants Eric Fleming and
Najuan Mack aggressively handcuffed him, breaking his arm and
causing other injuries. Sylvia Mathlock, J.R.'s mother,
now brings 42 U.S.C. § 1983 and state-law claims on
J.R.'s behalf. J.R. sues Fleming and Mack (both detention
center employees), Superintendent Leonard Dixon, the Office
of the Chief Judge, and Cook County. The Office of the Chief
Judge and Cook County move to dismiss all claims against
them, and Dixon moves to dismiss the § 1983
official-capacity claim against him. For the reasons
discussed below, these motions are granted.
motion to dismiss under Rule 12(b)(6) tests whether a complaint
states a claim for which relief may be granted. Fed.R.Civ.P.
12(b)(6). A plaintiff's “[f]actual allegations must
be enough to raise a right to relief above the speculative
level.” Bell Atlantic Corp. v. Twombly, 550
U.S. 544, 555 (2007). In other words, a “complaint must
contain sufficient factual matter, accepted as true, to
‘state a claim to relief that is plausible on its
face.'” Ashcroft v. Iqbal, 556 U.S. 662,
678 (2009) (quoting Twombly, 550 U.S. at 570). I
draw all reasonable inferences in favor of the non-movant.
Squires-Cannon v. Forest Preserve Dist. of Cook
Cty., 897 F.3d 797, 802 (7th Cir. 2018).
fifteen-year-old boy, was detained at the Cook County
Juvenile Temporary Detention Center.  ¶
Defendants Eric Fleming and Najuan Mack worked at the
detention center, where they were members of the Rapid
Response Team and responsible for ensuring safety and
security. Id. ¶¶ 4-5. On July 19, 2018,
Mack and Fleming aggressively handcuffed J.R., breaking his
arm in the process. Id. ¶ 22. J.R. suffered
extreme internal rotation of his arm, a displaced fracture of
the surgical neck of his right humerus, and a broken humerus
head. Id. ¶ 23. In addition to his physical
pain and suffering, the incident caused J.R. emotional
distress. Id. ¶ 24.
Leonard Dixon was the superintendent at the time of the
incident. Id. ¶ 6. As superintendent, Dixon
oversaw, supervised, and directed all functions of the
detention center. Id. ¶ 58. He was also the
chief architect of its policies and was responsible for
hiring, screening, training, retaining, supervising, and
disciplining all detention center employees. Id. The
Chief Judge of the Circuit Court of Cook County appointed
Superintendent Dixon in May 2015. Id. ¶ 19. His
appointment marked the end of a long transition period,
during which administrative authority over the detention
center was transferred from the Cook County Board to the
Office of the Chief Judge. That transition began in 1999,
when the ACLU filed a federal civil rights class action
against Cook County alleging systemic mistreatment and
neglect at the detention center. Id. ¶ 15.
Eight years later, after determining that Cook County was not
complying with the terms of the resulting settlement
agreement, the district court appointed a transitional
administrator to operate the detention center and bring it
into compliance with the court's orders. Id.
¶ 16. The court also tasked the administrator with
transitioning administrative authority over the detention
center to the Office of the Chief Judge of the Circuit Court
of Cook County. Id. A few months later, the Illinois
legislature passed a similar bill, transferring
administrative authority of the Cook County Juvenile
Temporary Detention Center to the Office of the Chief Judge.
Id. ¶ 17. The bill became effective January 1,
2008, though the detention center remained under control of
the court's temporary administrator until 2015, when the
court ordered that control be transferred to the Office of
the Chief Judge. Id. ¶¶ 17-18.
Office of the Chief Judge and Cook County move to dismiss the
§ 1983 and respondeat superior claims, and Cook County
asserts it is not a necessary party for indemnification
purposes. Dixon moves to dismiss only the § 1983 claim
against him in his official capacity.
complaint alleges that the Office of the Chief Judge, Dixon,
and Cook County are liable under a Monell theory for
Mack's and Fleming's use of excessive force. More
specifically, it alleges that the three government defendants
failed to hire, train, and supervise detention center
employees to prevent their unnecessary use of force.
Defendants argue both that the Eleventh Amendment bars the
§ 1983 claim and that the complaint fails to allege a
policy or practice as required to state a Monell
Eleventh Amendment Immunity
the Eleventh Amendment bars suits against states but not
against local governments, the parties' dispute centers
on whether administering the Juvenile Temporary Detention
Center is a state or county function. (In Illinois, the Office of
the Chief Judge is a state entity. See Drury v. McLean
Cty., 89 Ill.2d 417, 427 (1982).) Defendants argue that
the chief judge controls the detention center, making it an
arm of the state and barring the § 1983 suit for
damages. See Scott v. O'Grady, 975 F.2d 366, 369
(7th Cir. 1992) (noting that the Eleventh Amendment extends
immunity to state officials sued in their official
capacities). J.R. asserts that Cook County operates the
detention center and that, therefore, the Eleventh Amendment
does not bar his claims. J.R. does not dispute that as the
superintendent, Dixon's actions represent official
policy. See McMillian v. Monroe Cty., Ala., 520 U.S.
781, 785 (1997). In determining whether Dixon acted as an arm
of the state, then, the relevant question is whether he is a
final policymaker for Illinois or Cook County on the
particular issue of hiring, training, and supervising
detention center employees. Id. The question is not
whether he is a state official “in some categorical
‘all or nothing' manner.” Id.
the chief judge and the county manage different aspects of
the detention center. To determine whether the detention
center functions as an arm of the state for Eleventh
Amendment purposes, I consider the extent of its financial
autonomy from the state and its general legal status.
Tucker v. Williams, 682 F.3d 654, 659 (7th Cir.
2012); Hess v. Port Auth. Trans-Hudson Corp., 513
U.S. 30, 47 (1994) (“When indicators of immunity point
in different directions, the Eleventh Amendment's twin
reasons for being remain our prime guide.”). The latter
inquiry-the general legal status of the center-requires
analyzing state law; though an official's ...