James Hunt v. City of Chicago, David Brown, and Larry Snelling

CourtDistrict Court, N.D. Illinois
DecidedMarch 30, 2026
Docket1:23-cv-00522
StatusUnknown

This text of James Hunt v. City of Chicago, David Brown, and Larry Snelling (James Hunt v. City of Chicago, David Brown, and Larry Snelling) 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
James Hunt v. City of Chicago, David Brown, and Larry Snelling, (N.D. Ill. 2026).

Opinion

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

James Hunt,

Plaintiff, NO. 1:23-CV-00522

v. Judge Edmond E. Chang

City of Chicago, David Brown, and Larry Snelling,

Defendants.

MEMORANDUM OPINION AND ORDER

James Hunt sued the City of Chicago, David Brown (the former Superinten- dent of the Chicago Police Department), and Larry Snelling (the current Superinten- dent) after he was allegedly reassigned from his role as a patrol officer to desk duty. R. 66, Second Am. Compl.1 Hunt brings a First Amendment retaliation claim, 42 U.S.C. § 1983, and a breach of contract claim for alleged violations of the Chicago Police Department’s collective bargaining agreement. Second Am. Compl. ¶¶ 50–71.2 The Defendants move to dismiss both claims. R. 67, Defs.’ Mot. For the reasons ex- plained below, the motion is denied as to the First Amendment retaliation claim, but the state law claim is dismissed with prejudice.

1Citations to the record are “R.” followed by the docket entry number and, if needed, a page or paragraph number.

2This Court has subject matter jurisdiction over the federal law claim under 28 U.S.C. § 1331, and supplemental jurisdiction over the state law claim under 28 U.S.C. § 1367(a). I. Background In evaluating the motion to dismiss, the Court “must accept as true all of the factual allegations contained in the complaint.” Erickson v. Pardus, 551 U.S. 89, 94

(2007) (per curiam). Hunt has been a police officer with the Chicago Police Depart- ment (which the parties call CPD) since 2013. Second Am. Compl. ¶ 14. Until 2018, Hunt worked as a beat patrol officer and then as a tactical officer in the Tactical Unit. Id. ¶¶ 15–16. Hunt alleges that in July 2018, he got into an altercation while arrest- ing a citizen and during which they exchanged coarse language. Id. ¶ 17. Bystanders captured the incident on video, and the arrested individual’s mother sent a complaint to the Civilian Office of Police Accountability (commonly referred to as COPA). Id.

¶ 18. Brown—who was Superintendent of CPD at the time—told Hunt that he had received a one-year suspension from COPA. Id. ¶ 19. Hunt alleges that COPA imple- ments and approves disciplinary actions with the explicit or implicit approval of the Superintendent. Id. ¶ 20. Hunt filed a grievance based on his suspension. Id. ¶ 21. His superiors denied the grievance, which led to arbitration. Id. Hunt was successful at arbitration and received a reduced suspension. Id.

After his suspension was over, CPD assigned Hunt to the Community Safety Unit (formerly known as the Gang Unit). Second Am. Compl. ¶ 22. Hunt then got into another incident with a citizen during a riot in May 2020. Id. ¶¶ 23–25. In March 2021, Hunt was reassigned from the Community Safety Unit to the Equipment and Supply Section (which Hunt says is essentially desk duty). Id ¶ 26. He does not know who gave the order to reassign him. Id. Someone later informed Hunt that he was 2 reassigned for his own protection. Id. ¶¶ 27–28. But Hunt alleges that he had never previously been informed of a threat, and the Commander of Labor Relations later testified that they kept Hunt off the street even after the threat expired. Id. Once on

desk duty, Hunt was also denied overtime and disqualified from promotions for which he claims he was otherwise qualified. Id. ¶ 29. In April 2021, Brown acknowledged in a media press conference that CPD had removed Hunt from the Community Safety Unit. Second Am. Compl. ¶ 31. Later that month and into May 2021, Hunt alleges that he was the only one in his unit (one of 10 officers) denied the opportunity for street deployment, and that CPD placed him on a “non-deployable” list without a hearing or adjudication. Id. ¶ 32. In August 2021,

COPA issued paperwork about Hunt’s second civilian incident and proceedings en- sued. Id. ¶ 33. In February 2022, Hunt was promoted to a Field Training Officer, but was then stripped from the position two days later pending the outcome of the COPA proceed- ings on his second incident. Second Am. Compl. ¶ 34. Hunt then became eligible for detective status in July 2022, which entails an automatic promotion with a sufficient

test score. Id. ¶ 38. But again, CPD did not promote Hunt because of the second civil- ian incident. Id. In December 2022, Hunt was placed on “no-pay” status based on that incident. Id. ¶ 35. He filed for unemployment with the Illinois Department of Em- ployment Security. Id. The Department granted unemployment benefits to Hunt, but the City appealed the decision. Id. In an administrative hearing on the matter, Hunt

3 “aired his grievances” with the CPD and successfully received unemployment bene- fits. Id. ¶¶ 36–37. In October 2023, the police board found Hunt not guilty in the second incident.

Second Am. Compl. ¶ 40. Snelling—who became Superintendent the month prior— appealed the decision despite testimony from the victim of the incident suggesting that Hunt was not involved. Id. ¶¶ 39–41. Hunt won on appeal again, but was de- tailed to “call-back” duty instead of reinstated to the field. Id. ¶ 42. “Call-back” detail is typically reserved for police who are under investigation, stripped of police powers, or restricted due to medical issues—none of which applied to Hunt. Id. ¶ 43. Hunt alleges that the Defendants sought to keep him on call-back duty indefinitely despite

him becoming eligible for multiple promotions in that time. Id. ¶ 44. Hunt says that he repeatedly complained to Snelling about the alleged retali- atory actions taken against him, but Snelling continued to approve each action. Sec- ond Am. Compl. ¶ 39. Hunt also made repeated complaints to the Human Resources sergeant, Anthony Rubens, and to his other supervisors. Id. ¶ 45. He also complained to his call-back sergeants and got no response. Id. ¶ 46. He submitted a form to the

Acting Commander of call-back requesting an end to his call-back detail. Id. ¶ 47. Hunt’s request was granted, but he never heard about it again after it was sent up the chain of command. Id. He tried moving to other police districts, but his superiors continuously placed him on call-back. Id. ¶ 48. Based on these events, Hunt sued the Defendants, alleging that they violated his procedural due process and equal protection rights, and breached CPD’s collective 4 bargaining agreement. R. 1, Compl. ¶¶ 28–46. Earlier in the case, the Court dis- missed Hunt’s constitutional claims without prejudice and declined to reach the state law claim. R. 39, Op. at 1–2. Hunt now brings claims for First Amendment retaliation

and breach of contract. Second Am. Compl. ¶¶ 50–71. II. Legal Standard Under Federal Rule of Civil Procedure 8(a)(2), a complaint generally need only include “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). This short and plain statement must “give the de- fendant fair notice of what the claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (cleaned up).3 The Seventh Circuit has

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