Bridges v. Dart

2024 IL App (1st) 231827-U
CourtAppellate Court of Illinois
DecidedDecember 13, 2024
Docket1-23-1827
StatusUnpublished

This text of 2024 IL App (1st) 231827-U (Bridges v. Dart) 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
Bridges v. Dart, 2024 IL App (1st) 231827-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (1st) 231827-U No. 1-23-1827 Order filed December 13, 2024 Sixth 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 DISTRICT ______________________________________________________________________________ DELPHINE BRIDGES, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County. ) v. ) No. 2018 CH 15535 ) THOMAS J. DART, in his official capacity as Sheriff of ) Cook County, and THE COOK COUNTY SHERIFF’S ) MERIT BOARD, ) Honorable ) Thaddeus Wilson, Defendants-Appellees. ) Judge, presiding.

JUSTICE C.A. WALKER delivered the judgment of the court. Justice Hyman and Justice Gamrath concurred in the judgment.

ORDER

¶1 Held: The Cook County Sheriff’s Merit Board’s finding that a correctional officer violated Sheriff’s orders was not against the manifest weight of the evidence and its decision to terminate her was not arbitrary or unreasonable. The circuit court’s judgment affirming the Board’s decision is affirmed.

¶2 Plaintiff Delphine Bridges appeals from the circuit court’s order affirming the decision of

Thomas J. Dart, Sheriff of Cook County (Sheriff), and the Cook County Sheriff’s Merit Board No. 1-23-1827

(Board) terminating her employment as a correctional officer. On appeal, Bridges contends that

the Board’s finding that she violated Sheriff’s orders was against the manifest weight of the

evidence, and her termination was arbitrary and unreasonable if premised on grounds other than

excessive use of force. We affirm.

¶3 BACKGROUND

¶4 Bridges was appointed as a correctional officer in the Cook County Sheriff’s Office

(CCSO) in 1990. In August 2015, she was assigned to Tier CC in Division 11 of the Cook County

Department of Corrections (CCDOC).

¶5 In August 2015, detainee Dale Carmer filed a detainee grievance report against Bridges,

asserting the use of force, and filed a complaint with the Cook County Sheriff’s Office of

Professional Review (OPR). In November 2015, OPR investigator Tia Parks-Jefferson was

assigned to investigate Carmer’s claim against Bridges. During her investigation, Parks-Jefferson

reviewed Carmer’s complaint and grievance report, an incident report, telephone calls, medical

records, and video recordings. She conducted interviews, which included interviews of Bridges,

detainee witnesses, and correctional staff witnesses.

¶6 On November 29, 2016, the Sheriff filed a complaint with the Board, seeking to terminate

Bridges. The Sheriff alleged that on August 24, 2015, Bridges engaged in “conduct unbecoming”

when she knocked Carmer’s property bag out of his hand and onto the floor. The Sheriff also

alleged that she used excessive force against Carmer, asserting she struck him in the face several

times, causing a right corneal abrasion injury. The Sheriff further alleged that Bridges failed to

ensure that Carmer received medical attention and to properly document her use of force and his

injuries. The Sheriff asserted that correctional officer Mario Robinson and correctional sergeant

-2- No. 1-23-1827

Milton Bozeman were present when the incident occurred, but Bridges failed to identify them as

witnesses. The Sheriff additionally alleged that Bridges gave false statements to OPR

investigators.

¶7 The Board held a hearing on June 11, July 20, August 1, and August 2, 2018. 1 At the

hearing, Parks-Jefferson testified about her investigation of the incident involving Bridges. As part

of her investigation, she had reviewed videos depicting the incident, showing different angles of

the jail hallway where the incident occurred. According to Parks-Jefferson, the videos corroborated

most of Carmer’s statement of the incident but did not capture Bridges striking Carmer. Parks-

Jefferson explained that the nature of the camera was that “it pans away *** it moves, so right as

the incident occurred, the camera panned away to a different location.” Parks-Jefferson narrated

the videos, identifying the people shown therein.

¶8 The videos were entered into evidence and this court has viewed them. One video (Camera

15) at 13:43:34 shows Bridges standing in the doorway between a room and a smaller hallway.

Bridges slaps a bag from Carmer’s hand before the camera pans away. Another video (Camera

16), showing the opposite side view of the area, depicts Bridges kicking that same bag. As this

happens, Robinson enters and Carmer stands in front of them with his hands at his sides, palms up

and open. Robinson attempts to handcuff Carmer with his hands in front of him. Bridges grabs

Carmer’s wrist, turns him around, and handcuffs him behind his back. A third officer and a

detainee enter the area just before the camera pans away.

1 The hearing also addressed complaints the Sheriff filed against Robinson and Bozeman, who are not parties to this appeal.

-3- No. 1-23-1827

¶9 Parks-Jefferson testified that during her interview with Bridges, which was played at the

hearing, Bridges denied striking Carmer. 2 Bridges also denied “slapping” Carmer’s bag from his

hands. Parks-Jefferson recounted that Robinson and Bozeman denied witnessing any use of force

by Bridges against Carmer during their OPR interviews. Parks-Jefferson found that Robinson and

Bozeman were not truthful to OPR in making those statements.

¶ 10 Parks-Jefferson concluded that Bridges used excessive force or unreasonable force against

Carmer, finding it was “more likely than not” that Bridges had struck Carmer. She based her

conclusion on Carmer’s statements to OPR, the corroborating detainee witness statements, and

video evidence, but noted the actual strike was not depicted in a video. Parks-Jefferson also found

that Bridges failed to document or file a report regarding her use of force. Parks-Jefferson further

found that Bridges had not been truthful during her OPR interview, because Bridges denied

slapping the bag from Carmer’s hands, which video evidence clearly depicted. Parks-Jefferson

noted that Carmer did not deny he had been very disrespectful and verbally abusive to Bridges and

called her a “b***.” However, Parks-Jefferson determined that Bridges striking Carmer in

response was not proper or reasonable and was not in compliance with the CCSO’s policies and

procedures.

¶ 11 On cross-examination, Parks-Jefferson testified that Carmer was medically diagnosed with

a corneal abrasion after the incident, which was consistent with a strike to the face. None of the

officers interviewed identified any visible injuries to Carmer’s face. Parks-Jefferson determined

that Carmer had not asked the officers present during the incident for medical attention.

2 The audio interview of Bridges was not made a part of the record on appeal. Bridges asserts in her reply brief that the audio interview is not necessary for appeal purposes as she does not contest that, during the interview, she stated she did not “slap” the bag.

-4- No. 1-23-1827

¶ 12 Detainee Patrick Twist testified as a witness to the incident involving Bridges and Carmer.

While standing in line to get new shoes, Twist observed Carmer and Bridges get into a verbal

altercation about whether Carmer’s name was called. Bridges instructed the officer passing out

shoes not to give any to Carmer. Bridges then ordered Carmer to go and pack his things, because

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Cite This Page — Counsel Stack

Bluebook (online)
2024 IL App (1st) 231827-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bridges-v-dart-illappct-2024.