Gutierrez v. City of Chicago

2025 IL App (1st) 240286-U
CourtAppellate Court of Illinois
DecidedAugust 28, 2025
Docket1-24-0286
StatusUnpublished

This text of 2025 IL App (1st) 240286-U (Gutierrez 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
Gutierrez v. City of Chicago, 2025 IL App (1st) 240286-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 240286-U Fourth Division Filed August 28, 2025 No. 1-24-0286

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

SALVADOR GUTIERREZ, ) ) Appeal from the Plaintiff-Appellant, Circuit Court of Cook County ) v. ) No. 2019 L 000533 ) THE CITY OF CHICAGO, a Municipal ) The Honorable Daniel A. Trevino, Corporation, ) Judge, presiding. Defendant -Appellee. )

JUSTICE OCASIO delivered the judgment of the court. Presiding Justice Rochford and Justice Lyle concurred in the judgment.

ORDER

¶1 Held: The judgment was affirmed where the general verdict rule would allow us to affirm because there is evidence to support the City’s theory of comparative negligence; and plaintiff was not prejudiced by the trial court prohibiting him from playing post- accident footage.

¶2 This matter arises from a negligence action filed against the City of Chicago, alleging that the

City’s failure to maintain a traffic signal light caused a crash that resulted in bodily injury to

plaintiff Salvador Gutierrez.

¶3 I. BACKGROUND

¶4 On January 16, 2019, Salvador Gutierrez filed a lawsuit against the City of Chicago and

Monica Ochoa, the driver of the SUV vehicle he crashed into, seeking recovery for injuries he No. 1-24-0286

sustained during a traffic incident. On April 11, 2019, an amended complaint was filed, alleging

that the City was negligent for not repairing the traffic control lights at the intersection in question

before the accident and for allowing the lights to function improperly. The City filed an answer to

the complaint denying that the City negligently failed to repair the lights at the intersection in

question and asserted Gutierrez’s comparative negligence as an affirmative defense. During

discovery Gutierrez named Gordon Meth as a liability expert and disclosed his opinions on August

18, 2021.

¶5 Ochoa was subsequently dismissed from the case, and Gutierrez proceeded to a jury trial

against the City.

¶6 A. The City’s Assertion of Immunity

¶7 A hearing on motions in limine was set for the Friday before trial, and the parties exchanged

their motions the afternoon before. Relevant here, the City sought to bar Gutierrez’s expert, Gordon

Meth, from testifying as to his opinions that the City should have (1) placed a sign at the

intersection where the collision occurred warning drivers that left-turn arrows were not active at

night, (2) inspected the traffic signal at that intersection to ensure it was operating correctly at

nighttime, and (3) chosen a single, round-the-clock signal plan rather than having a different signal

plan in place during nighttime hours. The City argued that this evidence should be barred because

it was immune from liability under various provisions of the Local Governmental and

Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/1-101 to 10-101

(West 2018)).

¶8 At the hearing on the motions in limine, the City also orally moved for leave to amend its

answer to raise affirmative defenses under the Tort Immunity Act, which corresponded to its

assertions that the testimony relating to certain of Meth’s opinions should be barred based on the

Tort Immunity Act under section 2-201 and 3-104. (745 ILCS 10/2-201, 3-104 (West 2018)). The

City claimed that the proposed amendment was aimed at countering any theories Meth might

present at trial. Gutierrez said that he was prepared for trial and it should proceed as planned.

-2- No. 1-24-0286

Gutierrez further asserted that an amendment to the answer raising new affirmative defenses at this

stage would be highly prejudicial and untimely and therefore should be denied. In reply, the City

argued that because Meth’s opinions emerged during discovery, it had not needed to assert the

immunity affirmative defenses in its original answer. The City further argued that the affirmative

defenses revealed the basis for its motions in limine that sought to prevent the admission of

evidence that related to alleged negligent acts which were immune from liability. The court pointed

to section 2-616(a) of the Code of Civil Procedure (735 ILCS 5/2-616 (West 2018)), which permits

parties to amend their pleadings at any time before final judgment is rendered on just and

reasonable terms. The court further noted that amendments to pleadings should be liberally allowed

so that cases could be decided on the merits, and it referenced the relevant factors as those set forth

in Loyola Academy v. S & S Roof Maintenance, Inc., 146 Ill. 2d 263 (1992). It granted leave to

amend “based on the information available to the court.”

¶9 The court then ruled on the motions in limine. Relevant here, it granted in part and denied in

part the City’s motion to exclude evidence about prior inspections, permitting Gutierrez to

introduce evidence pertaining to an inspection that had taken place the night before the incident

but barring evidence about any previous inspections under section 3-102 of the Tort Immunity Act.

(745 ILCS 10/3-104 (West 2018)). It also granted the City’s motion to bar Meth from opining on

its decision to implement a different signal plan at nighttime.

¶ 10 On the morning of trial, Gutierrez filed a written motion to strike the City’s Tort Immunity

Act defenses, arguing that the motion to amend did not meet the requirements of Loyola Academy.

The trial court denied the motion to strike.

¶ 11 B. Evidence Presented at Trial

¶ 12 1. The Collision

¶ 13 In general, the evidence at trial showed that, on June 15, 2018, at around 9:45 pm, Gutierrez

was riding his motorcycle eastbound on West Archer Avenue in Chicago. As Gutierrez approached

the traffic light at the intersection of Archer and South Mayfield Avenue, he changed lanes from

-3- No. 1-24-0286

the left lane to the right lane. The light for eastbound Archer was red as Gutierrez neared the

intersection. Meanwhile, a Kia SUV driven by Ochoa was stopped in the left turn lane on

westbound Archer, which also had a red light, preparing to turn left into a Jewel Osco parking lot

connected to southbound Mayfield. Joshua Trujillo, a passenger in Ochoa’s car, and Chicago police

officer John Weinert, who was approaching the intersection in a patrol car headed westbound on

Archer, witnessed the subsequent collision between Gutierrez’s motorcycle and Ochoa’s SUV.

¶ 14 When the lights for westbound Archer turned green, a yellow left-turn arrow—not a green

one—illuminated at the same time. Ochoa began executing a left turn, while the cars in the two

eastbound lanes of Archer remained stopped. While Ochoa was making the turn, the yellow arrow

turned off. Meanwhile, Gutierrez bypassed the halted eastbound cars by riding along the curbside

and entered the intersection before Ochoa had cleared it. He collided with the front right side of

Ochoa’s vehicle.

¶ 15 Officer Weinert and his partner, Officer Matthew Bos, went to Gutierrez’s aid, and they were

shortly joined by other first responders, who ultimately took Gutierrez to a hospital for his injuries

to be treated. Both officers activated their body-worn cameras.

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2025 IL App (1st) 240286-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gutierrez-v-city-of-chicago-illappct-2025.