DeAngelo v. Veach et al
Filing
62
MEMORANDUM OPINION and ORDER: For the reasons stated herein, we grant Defendants' motion for summary judgment on Count I's excessive force claim and on Count II. (Dkt. No. 44 .) Defendants' motion for summary judgment on Count I is denied as to Plaintiff's unreasonable seizure claim. Civil case terminated. Signed by the Honorable Marvin E. Aspen on 2/11/2019. Mailed notice (ags, )
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
MATTHEW DEANGELO,
Plaintiff,
v.
VILLAGE OF ROSEMONT, DANIEL
VEACH, JOSEPH ALBANDIA, and
MONTERREY SECURITY
CONSULTANTS, INC.,
Defendant.
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No. 1:17 C 2571
Hon. Marvin E. Aspen
MEMORANDUM OPINION AND ORDER
MARVIN E. ASPEN, District Judge:
Plaintiff Matthew DeAngelo filed this action against the Village of Rosemont (the
“Village”), Officer Daniel Veach, Officer Joseph Albania (together, the “Officers”), and
Monterrey Security Consultants, Inc. (“Monterrey”), asserting a claim under 42 U.S.C. § 1983
for unreasonable seizure and use of excessive force (Count I), as well as state-law battery
(Count II) and malicious prosecution (Count III) claims. Presently before us is the Village and
the Officers’ motion for summary judgment on Counts I and II of Plaintiff’s complaint. 1 For the
reasons set forth below, we grant the motion in part and deny it in part.
BACKGROUND
On August 6, 2016, Plaintiff visited Adobe Gila’s, a restaurant and bar located at MB
Financial Park in Rosemont, Illinois. 2 (SOF ¶¶ 13–14, 32.) The Village contracted with
1
For the purposes of this motion for summary judgment, we refer to the Village and the Officers
as the “Defendants.”
2
Unless otherwise stated, the facts described herein are undisputed and culled from the parties’
Local Rule 56.1 statements of material facts and the attachments thereto (“SOF”). (See
Monterrey to provide private security services at MB Financial Park. (SOF ¶ 32;
PSAF ¶¶ 12–13; id., Ex. 2 (the “Agreement”) (Dkt. No. 55–2).) In the early morning hours of
August 7, 2017, Plaintiff had an encounter with a female bartender at Adobe Gila’s regarding a
spilled drink. (See Dep. of Matthew DeAngelo (“DeAngelo Dep”) at 39:1–47:3, SOF, Ex. D
(Dkt. No. 46–1) at Pg.ID#: 395–97.) Upset after the encounter, Plaintiff intentionally knocked
over a stack of napkins on the bar before returning to his group of friends with his drink. (Id.
at 46:2–46:12.) Shortly after returning to his group of friends, Plaintiff was approached by a
man wearing a black polo, who identified himself as a manager of Adobe Gila’s, and several
men wearing yellow shirts. (Id. at 47:4–48:6.) The man identifying himself as a manager asked
Plaintiff to leave the premises. (SOF ¶ 17; DeAngelo Dep. at 47:1–49:13.) Plaintiff walked over
to and stood by a stairway leading to the exit of Adobe Gila’s. (DeAngelo Dep. at 49:14–49:18.)
The individual who had identified himself as the manager and the men in yellow shirts again
approached Plaintiff and asked him to leave. (Id. at 50:11–50:18.) Plaintiff asked for a moment
to wait for his friends to catch up with him. (Id. at 50:13–51:1.) Then, five to seven men red in
shirts, who Plaintiff believed to be Monterrey security guards, exited an elevator, approached
Plaintiff, and instructed him to leave the bar immediately. (Pl. Resp. to SOF ¶ 18; DeAngelo
Dep. at 31:3–33:10, 51:4–52:9.) Plaintiff again requested a moment to wait for his friends. (Pl.
Resp. to SOF ¶ 18; DeAngelo Dep. at 52:1–52:9.) Two of the men in red shirts then pulled
SOF (Dkt. No. 46); Pl.’s Resp. to SOF (Dkt. No. 54); Pl.’s Statement of Additional Disputed
Facts (“PSAF”) (Dkt. No. 55).) Because Defendants’ did not file a response to Plaintiff’s
statements of additional facts, we deem all material facts set forth in Plaintiff’s statement of
additional facts admitted. See L.R. 56.1(a) (“If additional material facts are submitted by the
opposing party pursuant to section (b), the moving party may submit a concise reply in the form
prescribed in that section for a response. All material facts set forth in the statement filed
pursuant to section (b)(3)(C) will be deemed admitted unless controverted by the statement of the
moving party.”).
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Plaintiff from the railing, and all of the guards pushed him to the ground.
(Pl.’s Resp. to SOF ¶¶ 18, 27; DeAngelo Dep. at 52:24–53:21.) Plaintiff felt the men in red
shirts hit and kick him while he was on the ground before placing him in handcuffs. (DeAngelo
Dep. at 75:24–76:3, 86:15–21, 109:1–5.)
The men assisted Plaintiff off the ground and escorted him in handcuffs to an elevator
and then to a room with two desks and a metal bench in the nearby parking garage of MB
Financial Park. (SOF ¶¶ 19–20; DeAngelo Dep. at 54:15–57:6.) There were two male police
officers in Rosemont Police Department uniforms present in the parking garage room when
Plaintiff arrived. (SOF ¶ 20; DeAngelo Dep. 57:21–58:10.) The Rosemont Public Safety
Incident Report lists the assigned officers as Daniel Veach and Joseph Albandia. (SOF, Ex. F
(Dkt. No. 46–1) at Pg.ID#: 558.) Plaintiff did not see any police officers at Adobe Gila’s before
he entered the parking garage room. (SOF ¶ 22.) An arrest report prepared by Officer Veach
indicates that he was dispatched to Adobe Gila’s for a “Criminal Trespass to Property.” (SOF,
Ex. F at Pg.ID#: 557.) Officer Veach then, per the incident report that he prepared, spoke with
Spiros Theodoropoulos, who stated that he had asked Plaintiff to leave Adobe Gila’s several
times asked Monterrey to remove Plaintiff when he refused. (Id. at Pg.ID#: 559.)
Theodoropolous, however, has no recollection of these events, though he stated that calling the
police would be typical practice where Adobe Gila’s staff were unable to remedy a situation.
(SOF ¶ 26; PSAF ¶ 3; Deposition of Spiros Theodoropolous (“Theodoropolous Dep.”) at 24:6–
24:13, 32:1–32:6, 39:5–39:8.)
The Officers searched Plaintiff’s pockets, took photos of him, and asked such questions
as his name, date of birth, and employment while Plaintiff remained handcuffed. (DeAngelo
Dep. at 57:10–16, 116:1–19.) One officer took photos while the other officer wrote the ticket for
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violation of the municipal trespass ordinance. (Id. at 60:5–60:18.) The Officers released
Plaintiff after he paid the cash bond. (SOF ¶ 29; DeAngelo Dep. at 122:1–122:14.) Plaintiff
remained in the parking garage room with the Officers for a total of ten to fifteen minutes.
(DeAngelo Dep. at 60:2–60:4.)
LEGAL STANDARD
Summary judgment is proper only when “there is no genuine dispute as to any material
fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). A genuine
dispute “exists when there is sufficient evidence favoring the non-moving party to permit a trier
of fact to make a finding in the non-moving party’s favor as to any issue for which it bears the
burden of proof.” Grant v. Trs. of Ind. Univ., 870 F.3d 562, 568 (7th Cir. 2017); see
Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S. Ct. 2505, 2510 (1986) (a genuine
issue for trial exists when “the evidence is such that a reasonable jury could return a verdict for
the nonmoving party”). In deciding whether summary judgment is appropriate, we must accept
the nonmoving party’s evidence as true and draw all reasonable inferences in that party’s favor.
Laskin v. Siegel, 728 F.3d 731, 734 (7th Cir. 2013); Anderson, 477 U.S. at 255,
106 S. Ct. at 2513. We do not “judge the credibility of the witnesses, evaluate the weight of the
evidence, or determine the truth of the matter. The only question is whether there is a genuine
issue of fact.” Gonzalez v. City of Elgin, 578 F.3d 526, 529 (7th Cir. 2009) (citing Anderson,
477 U.S. at 249–50, 106 S. Ct at 2511). “Where the record taken as a whole could not lead a
rational trier of fact to find for the non-moving party, there is no genuine issue for trial.”
Sarver v. Experian Info. Sols., 390 F.3d 969, 970 (7th Cir. 2004) (citation omitted).
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ANALYSIS
Defendants have moved for summary judgment on both of Plaintiff’s remaining claims:
Count I of his complaint against the Officers for violation of his constitutional rights pursuant to
42 U.S.C. § 1983 and Count II of his complaint against all defendants for state-law battery.
Respectively, the parties dispute whether the Officers had probable cause to seize Plaintiff and
whether Monterrey was the Village’s agents such that the Village may be held vicariously liable
for the Monterrey security guards’ alleged battery.
I.
COUNT I: EXCESSIVE FORCE AND UNREASONABLE SEIZURE
The Officers and the Village argue that summary judgment should be granted in their
favor with respect to Plaintiff’s § 1983 claim because the Officers did not use physical force
against Plaintiff and had probable cause to believe Plaintiff had committed trespass. (Mem. ¶ 11;
Reply (Dkt. No. 56) at 2.) In his response, Plaintiff abandons his excessive force claims against
the Officers, and we therefore grant Defendants’ motion for summary judgment on Count I
insofar as it relates to Plaintiff’s excessive force claim. (Pl.’s Resp. (Dkt. No. 53) at 2–3.)
However, Plaintiff maintains his claim under 42 U.S.C. § 1983 that the Officers violated his
“right to be free from unreasonable seizures . . . from state actors such as defendants Veach and
Albania, as protected by the Fourth and Fourteenth Amendments to the Constitution of the
United States.” (Compl. ¶ 26; see id. ¶¶ 25–30; see also Pl. Resp. at 4–5.)
A. Waiver
Defendants ask us to enter judgment in their favor on Count I in its entirety, but their
opening brief addresses only Plaintiff’s excessive force claim under 42 U.S.C. § 1983. (See
Mem. ¶ 11 (“It is undisputed that no police officer struck plaintiff. No police officer threw him
onto the floor. He was not handcuffed or escorted out of Adobe Gila’s by any police officer. He
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was issued an administrative violation ticket and was not charged criminally. Even viewing the
facts in the light most favorable to plaintiff, no harm was done to plaintiff by any police officer.
Plaintiff’s 42 U.S.C. § 1983 action cannot stand.”).) While their reply brief addresses Plaintiff’s
unreasonable seizure claim, arguments raised for the first time in a reply brief are generally
waived. Narducci v. Moore, 572 F.3d 313, 324 (7th Cir. 2009) (“[T]he district court is entitled
to find that an argument raised for the first time in a reply brief is forfeited.” (citing Cromeens,
Holloman, Sibert, Inc. v. AB Volvo, 349 F.3d 376, 389 (7th Cir. 2003))); see also, e.g., Alma
Garcia v. Draw Enters. III, LLC, 2018 WL 6045206, at *7 (N.D. Ill. Nov. 19, 2018) (“But by
failing to raise this argument until its reply brief, Draw forfeited the point for purposes of
summary judgment.”).
The waiver rule “is to ensure that the opposing party is not prejudiced by being denied
sufficient notice to respond to an argument.” Hernandez v. Cook Cty. Sheriff’s Office,
634 F.3d 906, 913 (7th Cir. 2011). Despite Defendants’ failure to address Plaintiff’s
unreasonable seizure claim in their opening brief, Plaintiff devoted most of his response brief to
arguments concerning his unreasonable seizure claim. (Pl.’s Resp. at 2–5.) Defendants’ reply
brief, while again limited, merely responds to Plaintiff’s arguments concerning his unreasonable
seizure claim. (Reply at 1–2.) We find that Plaintiff is not prejudiced by Defendants’ failure to
address his unreasonable seizure claim in their opening brief, and Defendants have not waived
their arguments regarding the same.
B. Unreasonable Seizure
The Fourth Amendment protects “[t]he right of the people to be secure in their
persons . . . against unreasonable . . . seizures.” U.S. Const. amend. IV. The “general rule” is
that “‘Fourth Amendment seizures are “reasonable” only if based on probable cause’ to believe
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that the individual has committed a crime.” Bailey v. United States, 568 U.S. 186, 192,
133 S. Ct. 1031, 1037 (2013) (quoting Dunaway v. New York, 442 U.S. 200, 213,
99 S. Ct. 2248, 2257 (1979)); see Matz v. Klotka, 769 F.3d 517, 522 (7th Cir. 2014). Officers
have probable cause to seize an individual when the “totality of the circumstances known” would
warrant a reasonable person believing the individual “had committed, was committing, or was
about to commit a crime.” Gutierrez v. Kermon, 722 F.3d 1003, 1008 (7th Cir. 2013) (citing
Abbott, 705 F.3d at 714). “This standard does not require that the officer’s belief turn out to be
correct; it need only be reasonable.” Bailey v. City of Chi., 779 F.3d 689, 694 (7th Cir. 2015)
(citing Texas v. Brown, 460 U.S. 730, 742, 103 S. Ct. 1535, 1543 (1983)); see also
Qian v. Kautz, 168 F.3d 949, 953 (7th Cir. 1999) (“This flexible, commonsense approach does
not require that the officer’s belief be correct or even more likely true than false, so long as it is
reasonable.” (citing Brown, 460 U.S. at 742, 103 S. Ct. at 1543)). Thus, “[t]he existence of
probable cause to arrest is an absolute defense to any § 1983 claim against a police officer for
false arrest or false imprisonment.” Abbott v. Sangamon Cty., Ill., 705 F.3d 706, 713–14
(7th Cir. 2013); see also Hurt v. Wise, 880 F.3d 831, 841 (7th Cir. 2018) (same).
Defendant argue that the Officers had probable cause to seize Plaintiff because, based on
the facts provided to them, “[c]learly there was probable cause to believe plaintiff was
trespassing.” (Reply at 2.) More specifically, Defendants argue the fact that Plaintiff “was
brought to them by security guards after being removed from Adobe Gila’s apparently against
his will” establishes the Officers’ probable cause to believe he had trespassed. Id.
Defendants have failed to show that no genuine issue of material fact remains as to
whether the Officers had probable cause to seize Plaintiff. As Plaintiff points out in his response
and statement of additional facts, that a “man was brought [the Officers] by security guards after
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being removed from Adobe Gila’s apparently against his will” does not tell the whole story.
(Reply at 2; see Resp. at 5 (describing the conflicting accounts of the facts known to the Officers
at the time of Plaintiff’s seizure).) For example, Defendant Veach created an “incident report,”
provided by Defendants as an exhibit to their statement of material facts, which appears to give a
different account of the totality of the circumstances known to the Officers when they seized
Plaintiff:
“Upon arrival, I spoke with Spiros Theodoropoulos who was working security at
Adobe Gilas, 5455 Park Pl. He stated that he had asked the offender, named
Matthew Isiah Deangelo to leave the bar several times, because he was being
unruly. The offender refused to leave the bar and Spiros notified Monterey security
to remove him from the Bar. The offender was relocated to the security holding
facility at MB Financial Park, 5501 Park Pl.”
(SOF, Ex. F at Pg.ID#: 559.)
Thus on the one hand, the Officers state that Plaintiff was simply brought to them in
handcuffs, yet on the other hand they describe “arriving” at Adobe Gila’s and having a
discussion with Theodoropolous regarding Plaintiff’s alleged trespass. (Id.; Reply at 2) This
account is further complicated given that Mr. Theodoropoulos denies any recollection of this
conversation with the Officers, and that the Officers now deny being dispatched to Adobe Gila’s
at all. (SOF, Ex. B at Pg.ID#: 366; PSAF ¶ 11.) Moreover, while the “incident report” provides
that Plaintiff “refused to leave the bar,” the police complaint states that he entered Adobe Gila’s
after being told to leave. (SOF, Ex. F at Pg.ID#: 560; see also PSAF, Ex. 1 (Dkt. No. 55–1).)
These issues of fact go directly to the totality of the circumstances known to the Officers at the
time they seized Plaintiff for trespassing and thus to whether they had probable cause to do so.
Because these genuine issues of material fact remain, we deny Defendants’ motion for summary
judgment on Plaintiff’s unreasonable seizure claim set forth in Count I of his complaint.
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II.
COUNT II: STATE LAW BATTERY CLAIM
Defendants argue they are entitled to judgment on Plaintiff’s state-law battery claim
because the undisputed material facts show that the Officers did not attack Plaintiff.
(Mem. ¶ 12.) Plaintiff concedes that there is no valid claim for battery against the Officers.
(Pl.’s Resp. at 5.) Plaintiff contends, however, that the Village is liable for the actions of the
Monterrey security guards under a respondeat superior theory. (Id. at 5.) Plaintiff argues that a
contract between the Village and Monterrey to provide security services at MB Financial Park
indicates that Monterrey, and thus its security guards, were the Village’s agents. (Id.)
Defendants contend that Plaintiff did not include the theory of respondeat superior in his
complaint, and therefore Plaintiff cannot rely on the theory at this stage. (Reply at 3.)
Defendants further urge that even if Plaintiff’s respondeat superior theory is available, it is
without merit because the Agreement stated that Monterrey was an independent contractor and
thus not an agent for which the Village would have respondeat superior liability. 3 (Id. at 3–4).
A. Waiver
As an initial matter, Plaintiff adequately put the Village on notice of his respondeat
superior theory against the Village of Rosemont in his complaint. The doctrine of respondeat
superior provides that a principal or employer may be held liable for the acts undertaken by its
agent or employee within the scope of his agency or employment. Lawlor v. N. Am. Corp. of Ill.,
2012 IL 112530, ¶ 42, 983 N.E.2d 414, 427 (Ill. 2012); Lang v. Silva, 306 Ill. App. 3d 960, 972,
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Defendants again did not raise these arguments until their reply. However, given that the scope
of their reply on the issue is limited to Plaintiff’s argument regarding the Village of Rosemont’s
respondeat superior liability, Plaintiff has not been prejudiced and we find that Defendants have
not waived their argument. See Hernandez, 634 F.3d at 913 (explaining that the waiver rule “is
to ensure that the opposing party is not prejudiced by being denied sufficient notice to respond to
an argument”).
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715 N.E.2d 708, 716 (1st Dist. 1999). Here, Plaintiff directly alleged a contractual relationship
between the Village and Monterrey to provide security at the location of the incident at issue.
(Compl. ¶ 7 (“Upon information and belief, the Village of Rosemont contracted with Monterrey
Security Consultants, Inc., to provide security at various Village owned venues, such as MB
Financial Park at 5501 Park Place in Rosemont, IL.”).) Plaintiff also alleged that the Village was
liable as a principal for torts committed by “its agents and employees,” not just the Village of
Rosemont police officers. (Id. ¶ 37 (“Defendant City Village of Rosemont is liable as a principal
on a respondeat superior basis for all state law torts committed by its agents and employees
against the plaintiff.”).) Plaintiff thus gave Defendant “fair notice” of his claim and “the grounds
upon which it rests”—that is, he adequately pleaded his claim for state-law battery against the
Village of Rosemont on the basis that it is liable for the actions of Monterrey security officers as
its agents. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555, 127 S. Ct. 1955, 1964 (2007)
(quoting Conley v. Gibson, 355 U.S. 41, 47, 78 S. Ct. 99, 103 (1957)).
B. Vicarious Liability
We must next determine whether there is a genuine dispute of material fact as to whether,
as Defendants argue, the Monterrey security guards were independent contractors and thus not
the Village’s agents. Plaintiff argues the Agreement establishes that the Monterrey security
guards were agents of the Village. (See PSAF ¶ 13 (“Based upon that contractual arrangement,
adopted pursuant to the Village of Rosemont’s powers authorized under the ‘home rule’
provisions of the Illinois Constitution, the Monterrey Security employees who attacked and
arrested Mr. DeAngelo were agents of the defendant Village of Rosemont at the time of the
incident at issue in this litigation.”).) While “[a]s a general rule, no vicarious liability exists for
the actions of independent contractors,” Lawlor, 2012 IL 112530, ¶ 42, 983 N.E.2d at 427 (citing
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Petrovich v. Share Health Plan of Ill., Inc., 188 Ill. 2d 17, 31, 719 N.E.2d 756, 765 (Ill. 1999)),
liability is not precluded if the individual is also an agent, Id. ¶ 43, 983 N.E.2d at 427 (citing
Horwitz v. Holabird & Root, 212 Ill. 2d 1, 13, 816 N.E.2d 272, 279 (Ill. 2004)). “The
determination of whether a person is an agent or independent contractor rests upon the facts and
circumstances of each case.” Lawlor, 2012 IL 112530, ¶ 44, 983 N.E.2d at 427. While the right
to control the manner in which the work is performed is the most significant factor, courts should
also consider: “(1) the question of hiring; (2) the right to discharge; (3) the manner of direction
of the servant; (4) the right to terminate the relationship; and (5) the character of the supervision
of the work done.” Id. (citing Petrovich, 188 Ill. 2d at 46, 719 N.E.2d at 772).
Considering the language of the Agreement in the context of these factors, no reasonable
jury could find that Monterrey employees were the Village’s agents. The Agreement explicitly
defines Monterrey as an independent contractor and not an agent. (Agreement § 6.1 (“It is
understood and agreed that Monterrey acts solely as an independent contractor in providing
services pursuant to this Agreement. Nothing herein shall be construed to create the relationship
of employer and employee, partnership, principal or agent or joint venture between Monterrey
and Village.”).) Further, the Agreement indicates that Monterrey, not the Village, retains control
over the manner in which the work is performed. (Id. §§ 5.1, 5.3, 6.2 (“All employees of
Monterrey shall be subject to the direction, supervision and control of Monterrey. . . . Monterrey
is solely responsible for all acts and omissions of Monterrey agents and employees in providing
services under this Agreement . . . Monterrey shall be solely responsible for all means, methods
and techniques employed in providing security services pursuant to this Agreement.”).)
Specifically, while the Village requests particular dates and places for security services,
Monterrey oversees the scheduling of its employees. (Id. § 2.5 (“Monterrey shall be responsible
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for the scheduling of security personnel at the times and locations requested by the Village to
provide security services requested at a Village Event Venue.”).)
With respect to the other factors, although the Village retains the ability to prevent a
Monterrey employee from providing security services at a Village venue, the Agreement does
not provide the Village with the right to wholly discharge a Monterrey employee from
employment with Monterrey. (See Id. §§ 2.6, 7.3.) It is Monterrey, not the Village, that pays
wages and administers benefits to Monterrey employees. (Id. §2.11 (“Except as otherwise
expressly provided herein, Monterrey shall be responsible for all matters relating to the
employment of security personnel assigned to providing services . . . .”).) Monterrey also has
responsibility for the “training, licensing, and certification” and the “proper appearance and
conduct” of its employees. (Id. § 2.2.) Finally, Monterrey provides direct supervision of its
employees while they are on duty. (Id. §§ 5.1–5.3, 7.2.) See Dixon v. MB Real Estate Servs.,
LLC, 2016 IL App (1st) 152329-U, 2016 WL 3177987, ¶¶ 15–20 (1st Dist. June 7, 2016)
(holding that security guard was an independent contractor where contract between security
company and defendant identified guards as independent contractors and security company paid
salaries and benefits, provided guards with training and licensure, and scheduled and assigned
supervisors to oversee guards); Amigo’s Inn Inc. v. License Appeal Comm’n of City of Chi.,
354 Ill App. 3d 959, 966–67, 822 N.E.2d 107, 114–15 (1st Dist. 2004) (finding that bar security
guard was an independent contractor where bar did not directly pay, train, or provide uniforms or
assignments to guards although guards took direction from bar manager while on duty).
In sum, viewing the evidence in the light most favorable to Plaintiff, there exists no
dispute of material fact that Monterrey employees were not the Village’s agents. Therefore, the
Village cannot be liable for the actions of Monterrey employees on a respondeat superior basis.
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Because no reasonable jury could find that the Village was liable on a respondeat superior basis
for the actions of Monterrey employees and Plaintiff concedes the liability of Officers Veach and
Albandia for the state-law battery claim, the Defendants’ motion for summary judgment with
respect to Count II is granted.
CONCLUSION
For the above reasons, we grant Defendants’ motion for summary judgment on Count I’s
excessive force claim and on Count II. (Dkt. No. 44.) Defendants’ motion for summary
judgment on Count I is denied as to Plaintiff’s unreasonable seizure claim. It is so ordered.
____________________________________
Marvin E. Aspen
United States District Judge
Dated: February 11, 2019
Chicago, Illinois
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