McBride v. McLean County

CourtDistrict Court, C.D. Illinois
DecidedOctober 12, 2021
Docket1:18-cv-01424
StatusUnknown

This text of McBride v. McLean County (McBride v. McLean County) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McBride v. McLean County, (C.D. Ill. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION

LAURA MCBRIDE, ) ) Plaintiff, ) ) v. ) Case No. 1:18-cv-1424 ) CARLA BARNES, ) ) Defendant. )

OPINION AND ORDER Pending before the Court is Defendant Carla Barnes’s Motion for Summary Judgment. ECF No. 45. Plaintiff filed a response and Defendant filed a reply. Accordingly, this motion is ripe for review. For the reasons stated below, Defendant’s Motion for Summary Judgment is DENIED. PROCEDURAL BACKGROUND In November of 2018, Plaintiff filed a Complaint against Defendant Carla Barnes and the now dismissed Defendants Bill Wasson and McLean County. She initially filed a pro se Complaint and later retained an attorney who filed an Amended Complaint. Plaintiff’s claims relate to the elimination of her position in 2017. The Amended Complaint named the same Defendants as the pro se Complaint and claimed: (1) a First Amendment violation under 42 U.S.C. § 1983 against Barnes and Wasson; (2) a First Amendment conspiracy under 42 U.S.C. § 1983 against Barnes and Wasson; (3) a section 1983 Monell claim for violation of Plaintiff’s First Amendment rights against all Defendants; and (4) a violation of the Illinois Whistleblower Act, 730 ILCS 174/20.1, against all Defendants. Defendants filed a Motion to Dismiss Plaintiff’s Amended Complaint under Federal Rule of Civil Procedure 12(b)(6). ECF No. 17. The Court dismissed all the claims against Bill Wasson and McLean County and Counts Two and Three against Defendant Barnes. The only remaining claims are Count One brought under the First Amendment and Count Four under the Illinois Whistleblower Act against Defendant Barnes. The parties exchanged discovery and Defendant Barnes filed a Motion for Summary Judgment. This opinion follows.

FACTUAL BACKGROUND This action stems from the December 31, 2017 termination of Plaintiff’s employment as a Criminal Defense Investigator in the Public Defender’s Office. Plaintiff contends that Defendant Barnes made the decision to terminate Plaintiff by using the pretext of budgetary concerns after Plaintiff spoke out on how former Public Defender Kim Campbell (“Campbell”) may have improperly aided the prosecution in the murder trial of People v. David Boswell, Jr., 2010 CF 1117 and of how Defendant Barnes, lead trial counsel for Boswell and later, the Public Defender, failed to report Campbell’s actions from that trial. ECF No. 46 at 50. Plaintiff points to August 2011 as the precipitation of events that ultimately led to her termination. In August 2011, Plaintiff testified in a professional capacity in the Boswell trial. ECF

No. 46 at 4. Defendant Barnes was lead counsel for Boswell, and Campbell was Defendant’s supervisor. After closing arguments, Campbell allegedly told Plaintiff that she had helped the Assistant State’s Attorney write her closing argument. ECF No. 50 at 7. Boswell, the criminal defendant, was found guilty. Plaintiff reported Campbell’s statement to Defendant Barnes, who noted that she had suspected that Campbell was assisting the prosecutors, but nonetheless declined to report Campbell. Id. at 7–8. Defendant Barnes told Plaintiff that she discussed it with co-counsel Brian McEldowney the same day and the two agreed that they did not need to report the information. Id. at 8. It appears that information remained private until 2014. In April 2014, Plaintiff met with the McLean County State’s Attorney due to concerns that Campbell was improperly using public funds and resources. ECF No. 46 at 5. Plaintiff ultimately brought her concerns to Chief Judge Elizabeth Robb. On July 22, 2014, Plaintiff met with Chief Judge Robb and also told her about

Campbell’s involvement with the Boswell trial and Defendant Barnes’s knowledge of it. ECF Nos. 46 at 5; 50 at 2. In September 2014, Plaintiff signed an affidavit prepared by Judge Robb regarding the Boswell trial and included in that affidavit that she reported the incident to Defendant Barnes. ECF Nos. 45-6; 46 at 20. The parties appear to agree that Defendant Barnes was aware of the contents of the affidavit, specifically that Plaintiff claimed that Defendant knew of Campbell’s misconduct in the Boswell case and chose not to report it. ECF No. 46 at 6. Campbell was eventually ousted from office due to the scandal involving her misappropriation of funds. ECF No. 45 at 5. It appears that at that time, Campbell and Defendant Barnes’s misconduct regarding the Boswell trial was still not publicly known. In 2014, Defendant Barnes was selected to serve as the new McClean County Public Defender. ECF No. 46 at 7. When

Defendant was promoted, she and Plaintiff were still good friends in addition to being colleagues. ECF No. 46 at 24. Defendant Barnes, in fact, stood up in Plaintiff’s 2007 wedding and Plaintiff claims they continued to be friends long after Defendant was appointed to McLean County Public Defender and became the boss of the office. Id. The two vacationed together as recently as February 2016. Id. However, in March of 2016, Plaintiff’s accusations regarding Campbell’s inappropriate conduct in the Boswell trial became public in a newspaper article published in The Pantagraph. ECF No. 45-7. The article outlined how the defendant in the Boswell trial was seeking a new trial due to Campbell’s misconduct. Id. While Defendant was not mentioned in the article, the article referenced the affidavit where Plaintiff claimed she had informed Defendant of Campbell’s misconduct. Id. Plaintiff claims that shortly after the article was published, Defendant stated that she was worried about the future of her career. ECF No. 45-1 at 21. Plaintiff testified that Defendant felt concern about the affidavit being available and that it contained information that

Defendant knew about Campbell’s misconduct since the trial had ended. ECF No. 45-1 at 21. Defendant also admits that while she was on vacation, she received a call from the author of The Pantagraph article but that she had missed the call. ECF Nos. 50 at 100; 45-1 at 20. Plaintiff argues that Defendant was a young lawyer with ambitions to higher office and would be unhappy to have her participation in this conflict of interest play out in the press and in public court proceedings. ECF No. 46 at 40. She states that Defendant’s fears were eventually realized in an Illinois Appellate Court opinion in the Boswell postconviction proceedings where the Appellate Court stated that Plaintiff’s affidavit supported an inference that “there was a defect in Barnes’s decision- making that was attributable to her conflicting loyalties to defendant and her employer.” People v. Boswell, 2020 IL App (4th) 180165, ¶ 26, 2020 WL 7654079, at *5 (Ill. App. 4 Dist., 2020).

Accordingly, the Illinois Appellate Court agreed that Defendant Barnes had an actual conflict of interest and granted Boswell an evidentiary hearing on his conflict-of-interest claim. Id. Plaintiff claims that after the article, her once warm friendship and professional relationship with Defendant turned tense. ECF No. 45-1 at 22. Plaintiff claims that Defendant stopped speaking to her about personal matters, they stopped texting, and they stopped communicating as much in the office. Id. If they needed to communicate about work, Defendant would generally leave Plaintiff a note in her bin. Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Connick Ex Rel. Parish of Orleans v. Myers
461 U.S. 138 (Supreme Court, 1983)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Behrens v. Pelletier
516 U.S. 299 (Supreme Court, 1996)
Borough of Duryea v. Guarnieri
131 S. Ct. 2488 (Supreme Court, 2011)
Sandra L. Waldridge v. American Hoechst Corp.
24 F.3d 918 (Seventh Circuit, 1994)
Cynthia D. Traylor v. Kirk Brown
295 F.3d 783 (Seventh Circuit, 2002)
Barbara Payne v. Michael Pauley
337 F.3d 767 (Seventh Circuit, 2003)
John Zaccagnini v. Chas. Levy Circulating Co.
338 F.3d 672 (Seventh Circuit, 2003)
Valentino v. Village of South Chicago Heights
575 F.3d 664 (Seventh Circuit, 2009)
Woodruff v. Mason
542 F.3d 545 (Seventh Circuit, 2008)
Corning v. East Oakland Township
670 N.E.2d 350 (Appellate Court of Illinois, 1996)
Harinek v. 161 North Clark Street Ltd. Partnership
692 N.E.2d 1177 (Illinois Supreme Court, 1998)
Murray v. Chicago Youth Center
864 N.E.2d 176 (Illinois Supreme Court, 2007)
Johnson v. Mers
664 N.E.2d 668 (Appellate Court of Illinois, 1996)
Zinnermon v. City of Chicago Department of Police
209 F. Supp. 2d 908 (N.D. Illinois, 2002)
People v. Boswell
2020 IL App (4th) 180165 (Appellate Court of Illinois, 2020)
Hagan v. Quinn
84 F. Supp. 3d 826 (C.D. Illinois, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
McBride v. McLean County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcbride-v-mclean-county-ilcd-2021.