Babnik v. Village of Antioch

CourtDistrict Court, N.D. Illinois
DecidedMarch 31, 2025
Docket1:21-cv-00022
StatusUnknown

This text of Babnik v. Village of Antioch (Babnik v. Village of Antioch) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Babnik v. Village of Antioch, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

SCOTT BABNIK, individually and on behalf of all others similarly situated, ) ) Plaintiff, ) No. 21 C 00022 ) v. ) ) THE VILLAGE OF ANTIOCH, ) Judge Jeffrey I. Cummings LARRY HANSON, JAMES KEIM, ) RICK MORITZ, ) TOM NOWOTARSKI, ) GEOFF GUTTSCHOW and ) ROBERT LONG, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

Plaintiff Scott Babnik (“Babnik”) brings this case individually, and on behalf of all others similarly situated, against the Village of Antioch (“Village”) and six individuals it employed1 (collectively, “defendants”), seeking legal and equitable relief. In his four-count amended complaint, (Dckt. #47), Babnik asserts that defendants: (1) violated his Fourth Amendment rights; (2) violated his rights under the Federal Wire and Electronic Communications Interception Statute (18 U.S.C. §§2511, 2520); (3) violated his rights under the Illinois Eavesdropping Act (720 ILCS 5/14-2); and (4) invaded his right to privacy under Illinois common law. Defendants bring motions to dismiss the complaint, (Dckt. ##53, 55), for lack of subject matter jurisdiction and for failure to state a claim pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), respectively. For the reasons set forth below,

1 Namely, Larry Hanson (the Village Mayor), James Keim (the Village Administrator), Robert Long (the Village’s Attorney), Geoff Guttschow (the Chief of Police), Tom Nowotarski (Village PD officer and head of the investigations section), and Rick Moritz (the Village PD commander). (Dckt. #47 ¶¶26–33). defendants’ motions to dismiss the amended complaint are granted for failure to state a claim, and plaintiff is granted leave to file a second amended complaint on or before April 25, 2025. I. LEGAL STANDARD A. Federal Rule of Civil Procedure 12(b)(1) A motion under Federal Rule of Civil Procedure 12(b)(1) seeks dismissal based on the

court’s lack of subject matter jurisdiction. “The Court starts with standing, which ‘is a threshold question in every federal case because if litigants do not have standing to raise their claims the court is without authority to consider the merits of the action.’” Ill. Conservative Union v. Illinois, No. 20 CV 5542, 2021 WL 2206159, at *3 (N.D.Ill. June 1, 2021), quoting Meyers v. Nicolet Rest. of De Pere, LLC, 843 F.3d 724, 726 (7th Cir. 2016). This is so because “Article III of the Constitution limits federal judicial power to certain ‘cases’ and ‘controversies,’ and the ‘irreducible constitutional minimum’ of standing contains three elements.” Silha v. ACT, Inc., 807 F.3d 169, 172–73 (7th Cir. 2015), quoting Lujan v. Defs. Of Wildlife, 504 U.S. 555, 559-60 (1992). In particular, “a plaintiff must show (1) it has suffered an ‘injury in fact’ that is (a)

concrete and particularized and (b) actual or imminent, not conjectural or hypothetical; (2) the injury is fairly traceable to the challenged action of the defendant; and (3) it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.” Friends of the Earth, Inc. v. Laidlaw Env’t. Servs. (TOC), Inc., 528 U.S. 167, 180–81 (2000); Silha, 807 F.3d at 173. In this case, defendants raise a facial challenge to subject matter jurisdiction by asserting that Babnik has not sufficiently alleged standing. Silha, 807 F.3d at 173. At the pleading stage, Babnik has the burden of clearly alleging facts demonstrating each element of Article III standing “for each claim that [he] press[es] and for each form of relief that [he] seek[s].” Dinerstein v. Google, LLC, 73 F.4th 502, 511 (7th Cir. 2023) (cleaned up); Lujan, 504 U.S. at 561. For purposes of defendants’ motions to dismiss, the Court accepts as true all well-pleaded facts in the complaint and draws all reasonable inferences in Babnik’s favor though it will “not accept as true statements of law or unsupported conclusory factual allegations.” Yeftich v. Navistar, Inc., 722 F.3d 911, 915 (7th Cir. 2013); McCauley v. City of Chicago, 671 F.3d 611,

616–19 (7th Cir. 2011) ( legal conclusions and conclusory allegations merely reciting the elements of claims are not presumed true for purposes of a motion to dismiss). Furthermore, “[b]ecause Lujan mandates that standing ‘must be supported in the same way as any other matter on which the plaintiff bears the burden of proof,’ it follows that the Twombly-Iqbal facial plausibility requirement for pleading a claim is incorporated into the standard for pleading subject matter jurisdiction.” Silha, 807 F.3d at 174, quoting Lujan, 504 U.S. at 561. As such, where a complaint pleads facts that are “merely consistent with” a plaintiff’s standing, it stops short of the line—which plaintiff must cross to plead standing— between possibility and plausibility. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Bell Atl. Corp.

v. Twombly, 550 U.S. 544, 557 (2007); Yeftich, 722 F.3d at 915; McCauley, 671 F.3d at 616. In other words, where the well-pleaded facts do not permit the court to infer more than the mere possibility of standing, plaintiff falls short of meeting his burden to plead standing. Iqbal, 556 U.S. at 678; Yeftich, 722 F.3d at 915. B. Federal Rule of Civil Procedure 12(b)(6) To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Hess v. Garcia, 72 F.4th 753, 758 (7th Cir. 2023) (cleaned up). “A claim has facial plausibility when it pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. Plausibility is not satisfied by mere “labels and conclusions,” “formulaic recitation of the elements of a cause of action,” or facts “merely consistent” with a defendant’s liability. Bell Atl. Corp., 550 U.S. at 545, 555. Instead, the plausibility standard “asks for more than a sheer possibility that a defendant has acted unlawfully,” Santana v. Cook Cnty. Bd. of Rev., 679 F.3d 614, 620–21 (7th Cir. 2012)

(cleaned up), and Babnik’s complaint “must actually suggest that he has a right to relief, by providing allegations that raise a right to relief above the speculative level,” Fuqua v. SVOX AG, 754 F.3d 397, 400 (7th Cir. 2014) (cleaned up) (emphasis in original). In other words, he must “nudge[] [his] claims across the line from conceivable to plausible.” Twombly, 550 U.S. at 570 (2007). II.

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Bluebook (online)
Babnik v. Village of Antioch, Counsel Stack Legal Research, https://law.counselstack.com/opinion/babnik-v-village-of-antioch-ilnd-2025.