Bailey v. City of Chicago

2026 IL App (1st) 251155-U
CourtAppellate Court of Illinois
DecidedJanuary 21, 2026
Docket1-25-1155
StatusUnpublished

This text of 2026 IL App (1st) 251155-U (Bailey v. City of Chicago) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bailey v. City of Chicago, 2026 IL App (1st) 251155-U (Ill. Ct. App. 2026).

Opinion

2026 IL App (1st) 251155-U

No. 1-25-1155

Order filed January 21, 2026

THIRD DIVISION

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

EVA BAILEY, through her mother Arturia Edwards, and ) Appeal from the ARTURIA EDWARDS, ) Circuit Court of ) Cook County Plaintiffs-Appellants, ) ) v. ) No. 25 L 2387 ) THE CITY OF CHICAGO, ) Honorable ) Michael F. Otto, Defendant-Appellee. ) Judge Presiding.

PRESIDING JUSTICE MARTIN delivered the judgment of the court. Justices Rochford and Reyes concurred in the judgment.

ORDER

¶1 Held: The trial court did not err when it denied leave to file an amended complaint.

¶2 At issue is whether the trial court abused its discretion in denying leave to amend a

complaint to add claims for negligent infliction of emotional distress allegedly caused by the City

of Chicago’s (City) failure to assist a mother in locating her missing daughter. The trial court

determined it would be futile to allow such an amendment as the claims would be barred by section

4-102 of the Local Governmental and Governmental Employees Tort Immunity Act (Tort No. 1-25-1155

Immunity Act) (745 ILCS 10/4-102 (West 2024)), which provides immunity to local public entities

“for failure to provide adequate police protection or service.” For the reasons that follow, we find

the trial court did not abuse its discretion and therefore affirm. 1

¶3 I. BACKGROUND

¶4 On December 11, 2023, nine-year-old Eva Bailey was reported missing by her mother

Arturia Edwards. Edwards was to pick Eva up at the end of the school day at a designated meeting

place. After waiting approximately fifteen minutes for Eva to arrive, Edwards went to the daycare

center that was responsible for Eva’s after-school transportation. There, a staff member was unable

to provide Edwards with any information concerning Eva’s whereabouts.

¶5 At approximately 4:10 p.m., Edwards dialed 911 and reported that her daughter was

missing. She requested that Chicago police issue an Amber Alert. The police dispatcher instructed

Edwards to remain at the daycare to await the arrival of police to assist her. After waiting ten

minutes, Edwards called 911 again and inquired why the police had not yet arrived.

¶6 No Chicago police met with Edwards at the daycare and no Amber Alert was issued.

Fortunately, police officers from the Oak Lawn Police Department found Eva after a concerned

resident reported a child knocking on their door and asking to use the phone to call her mother.

Mother and daughter were reunited approximately two hours after Eva was first reported missing.

¶7 On February 19, 2025, Edwards filed a complaint in the circuit court of Cook County

against the City.2 Edwards alleged that the City’s failure to assist in locating Eva and not issuing

an Amber Alert constituted a breach of the duty of care owed to citizens of Chicago. She alleged

1 In adherence with the requirements of Illinois Supreme Court Rule 352(a) (eff. July 1, 2018), this appeal has been resolved without oral argument upon entry of a separate written order. 2 The Chicago Police Department and the Office of Emergency Management Services were dismissed as defendants on the ground that they were “not suitable separate entities from the City of Chicago.” 2 No. 1-25-1155

that this breach proximately caused Eva to suffer emotional distress and mental anguish; and

proximately caused Edwards to suffer emotional distress and undue hardship.

¶8 On April 14, 2025, the City filed a combined motion to dismiss the complaint pursuant to

section 2-619.1 of the Code of Civil Procedure (Code) (735 ILCS 5/2-619.1 (West 2024)). This

section of the Code allows a movant to combine motions to dismiss under sections 2-615 (735

ILCS 5/2-615 (West 2024)) and 2-619 (735 ILCS 5/2-619 (West 2024)).

¶9 The City argued that dismissal was appropriate under section 2-615 on the ground that the

allegations in the complaint were conclusory and failed to state a cause action on which relief

could be granted. The City pointed out that “emotional distress,” in and of itself, is not a cause of

action. According to the City, Edwards appeared to be seeking relief under a theory of negligent

infliction of emotional distress but failed to plead sufficient facts to state such a cause of action.

The City also argued that Edwards failed to allege sufficient facts that would have supported the

issuance of an Amber Alert.

¶ 10 The City sought dismissal pursuant to section 2-619(a)(9) on the basis that the claims in

the complaint arose out of allegations of inadequate police services for which the City was immune

from liability under section 4-102 of the Tort Immunity Act. In addition, the City pointed out that

the incident occurred on December 11, 2023, and that Edwards filed her complaint on February

19, 2025. The City argued that the complaint should be dismissed under section 2-619(a)(5) on the

ground that the claims were time barred by the one-year statute of limitations found in section 8-

101(a) of the Tort Immunity Act (745 ILCS 10/8-101(a) (West 2024)).

¶ 11 In response, Edwards asserted that her claims were not barred, as she was not suing the

City “to provide police protection,” but rather “for breach of their own stated duty which is to

serve and protect the citizens of Chicago.” Edwards further contended that her claims were not

3 No. 1-25-1155

time barred, as she was not only pursuing damages “stemming from negligent infliction of

emotional distress,” but also for “loss of quality of life and undue hardship.” Edwards sought leave

to amend her complaint to add claims for negligent infliction of emotional distress and to set “forth

the factual support regarding this cause of action.” The City countered that granting Edwards leave

to amend her complaint to add these claims would be futile as the claims would be barred by

section 4-102 of the Tort Immunity Act.

¶ 12 On May 21, 2025, the trial court entered an order granting the City’s motion to dismiss

Edwards’ complaint with prejudice. The court dismissed the complaint pursuant to section 2-

619(a)(9), on the grounds that the claims in the complaint were barred by section 4-102 of the Tort

Immunity Act. The court also determined that the claims were time barred by the one-year statute

of limitations found in section 8-101(a) of the Tort Immunity Act. The court denied Edwards leave

to amend her complaint to add claims for negligent infliction of emotional distress, finding that

granting such an amendment would be futile, as the claims would be barred by section 4-102 of

the Tort Immunity Act. This timely appeal by Edwards followed.

¶ 13 II. ANALYSIS

¶ 14 On appeal, Edwards argues that the trial court erred in denying her leave to amend her

complaint to add claims for negligent infliction of emotional distress. The trial court dismissed the

complaint pursuant to section 2-619(a)(9) of the Code and denied leave to amend, finding that

granting such an amendment would be futile.

¶ 15 Section 2-619(a)(9) provides for dismissal of a pleading if “the claim asserted against

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Bluebook (online)
2026 IL App (1st) 251155-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bailey-v-city-of-chicago-illappct-2026.