Gauthier v. Chicago Board of Education

2024 IL App (1st) 230442-U
CourtAppellate Court of Illinois
DecidedJanuary 22, 2024
Docket1-23-0442
StatusUnpublished
Cited by1 cases

This text of 2024 IL App (1st) 230442-U (Gauthier v. Chicago Board of Education) 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
Gauthier v. Chicago Board of Education, 2024 IL App (1st) 230442-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (1st) 230442-U

No. 1-23-0442

Order filed January 22, 2024.

First 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 ______________________________________________________________________________

KENNY GAUTHIER, as mother and next friend ) Appeal from the of M.S., ) Circuit Court of ) Cook County. Plaintiff-Appellant, ) v. ) No. 2015 L 1766 ) CHICAGO BOARD OF EDUCATION, ) The Honorable ) John Simon, Defendant-Appellee. ) Judge Presiding. ______________________________________________________________________________

JUSTICE LAVIN delivered the judgment of the court. Presiding Justice Fitzgerald Smith concurred in the judgment. Justice Pucinski’s dissent to follow.

ORDER

¶1 Held: Plaintiff failed to demonstrate that the circuit court erred in granting summary judgment in defendant’s favor where plaintiff did not provide a complete record on appeal. We affirm.

¶2 Plaintiff Kenny Gauthier, as mother and next friend of M.S., appeals from the circuit

court’s order entering summary judgment in favor of defendant, the Chicago Board of Education,

on plaintiff’s claim for willful and wanton misconduct. On appeal, plaintiff contends that a No. 1-23-0442

genuine issue of material fact exists with respect to plaintiff’s assertion that defendant breached

its duty to keep students, including M.S., safe from known dangers. Plaintiff argues, among other

things, that defendant improperly allowed plaintiff’s assailant to remain in school despite

defendant’s knowledge that the assailant had a prior sexual encounter on school premises.

Plaintiff also asserts that the Local Governmental & Governmental Employees Tort Immunity

Act (Act) does not apply. See 745 ILCS 10/1-101 et seq. (West 2014). For the following reasons,

we affirm the circuit court’s judgment.

¶3 I. Background

¶4 On February 19, 2015, plaintiff filed a complaint alleging that defendant engaged in

willful and wanton misconduct with respect to an incident that occurred on April 2, 2014, at

Chicago Vocational Career Academy High School, which defendant owned and operated.

According to the complaint, M.S. was an intellectually disabled student who attended the school.

While at school, M.S. was touched in a sexual manner by another student, M.W. As a result,

M.S. threw up on M.W. In addition, defendant had known that other students had accused M.W.

of sexual abuse prior to this incident. Plaintiff further alleged that it was defendant’s duty to act

with reasonable care, to refrain from the reckless disregard of the students’ safety, and to refrain

from willful and wanton acts or omissions. Moreover, defendant breached its duty by subjecting

M.S. to criminal sexual abuse by a student who defendant knew to be a danger to other students.

In disregarding this duty, defendant acted willfully and wantonly, leading M.S. to sustain

injuries.

¶5 Defendant’s answer admitted that M.S. and another student were involved in an incident

of sexual misconduct. Defendant also admitted that M.W. was previously issued a misconduct

report and was suspended for inappropriate behavior. Defendant generally denied, however, that

2 No. 1-23-0442

the suspension followed prior allegations that M.W. sexually abused other students. Furthermore,

defendant essentially denied that it possessed, or violated, a duty to protect other students due to

knowledge that M.W. presented a danger.

¶6 Defendant’s answer also raised affirmative defenses under the Act. 745 ILCS 10/2-201,

3-108 (West 2014). As for section 2-201, defendant claimed that as a local public entity, it was

not liable for an injury resulting from an act or omission in determining policy or an exercise of

discretion. Furthermore, section 3-108 provided immunity for injuries resulting from a failure to

supervise an activity.

¶7 Following discovery, defendant filed a motion for summary judgment, arguing that the

Act immunized defendant’s alleged misconduct under not only sections 2-201 and 3-108, but

sections 4-102, 2-103 and 2-205 as well. See 745 ILCS 10/4-102, 2-103, 2-205 (West 2014).

Defendant asserted that section 4-102 immunized defendant for failing to provide police

protection service to prevent the commission of crimes. In addition, sections 2-103 and 2-205

immunized defendant for the failure to enforce any law or adopt any policy, and provided them

with absolute immunity with respect to willful and wanton misconduct. Moreover, defendant

argued that a party generally has no duty to prevent the criminal acts of another, and the “special

relationship” exception did not apply here.

¶8 Several items were attached to defendant’s motion, such as M.S.’s Individualized

Education Plan (IEP Plan) and the transcripts of the depositions of M.S., his mother, Principal

Douglas Maclin, Dean Lloyd Batts, and Assistant Principal Donna Harris. Only the IEP plan,

however, is included in our record on appeal.

¶9 In response, plaintiff argued that defendant did not enjoy broad immunity under section

2-201. Additionally, section 3-108 did not apply because defendant’s conduct was willful and

3 No. 1-23-0442

wanton, as defendant’s knowledge of M.W.’s prior conduct created a duty to protect M.S., but

defendant had disregarded M.S.’s safety. Plaintiff further argued that sections 2-103 and 2-205

did not apply because plaintiff was not alleging that defendant failed to enforce or adopt a policy,

but instead, maintained that defendant had engaged in willful misconduct by allowing a student

known to engage in oral sex at school to remain there. As to section 4-102, the case at hand

involved the inability of school staff to provide supervision and protection, not the absence of

police protection. Plaintiff argued that at a minimum, a genuine issue of material fact remained,

precluding summary judgment.

¶ 10 The circuit court granted defendant’s motion for summary judgment, “[f]or the reasons

stated in open court.” The report of proceedings, however, is not included in our record on

appeal. See Ill. S. Ct. R. 321 (Oct. 1, 2021); Ill. S. Ct. R. 323 (eff. July 1, 2017).

¶ 11 II. Analysis

¶ 12 On appeal, plaintiff asserts that the circuit court erred by entering summary judgment in

defendant’s favor, as defendant is not entitled to immunity under the statutes in question.

¶ 13 Summary judgment should be granted when the pleadings, depositions and admissions on

file, together with the affidavits, if any, establish that there is no genuine issue of material fact,

and that the moving party is entitled to a judgment as a matter of law. 725 ILCS 5/2-1005(c)

(West 2014). Conversely, a triable issue of fact precluding summary judgment exists where the

material facts are disputed or where the material facts are undisputed, but reasonable persons

might draw different inferences from those facts. Simmons v. Reichardt, 406 Ill. App. 3d 317,

321 (2010). When reviewing an order granting summary judgment, we must determine whether,

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Related

Gauthier v. Chicago Board of Education
2024 IL App (1st) 230442-U (Appellate Court of Illinois, 2024)

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