Navarro-Angulo v. Police Board of the City of Chicago

Appellate Court of Illinois·Decided July 31, 2026·No. 1-25-2229·Unpublished

Opinion

2026 IL App (1st) 252229-U

FIFTH DIVISION July 31, 2026

No. 1-25-2229

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

EDGAR RAFAEL NAVARRO-ANGULO, ) ) Appeal from the Plaintiff-Appellant, ) Circuit Court of ) Cook County v. ) ) No. 2025CH03343 POLICE BOARD OF THE CITY OF CHICAGO, ) CHICAGO POLICE DEPARTMENT, AND THE ) The Honorable OFFICE OF PUBLIC SAFETY ADMINISTRATION, ) Patrick T. Stanton, Judge Presiding. Respondents-Appellees.

JUSTICE WILSON delivered the judgment of the court. Justices Mikva and Oden Johnson concurred in the judgment.

ORDER

¶1 Held: The Police Board properly disqualified the appellant from eligibility as a probationary police officer. The appellant failed to show that his removal from the eligibility list was erroneous, and the agency’s procedures complied with due process.

¶2 Appellant Edgar Rafael Navarro-Angulo applied for a probationary police officer position

with the Chicago Police Department (CPD). As part of the application process, Chicago’s Office

of Public Safety Administration (OPSA) conducted a background investigation. After the

investigation, Navarro-Angulo was removed from CPD’s employment eligibility list based on past No. 1-25-2229

criminal conduct and dishonesty. Navarro-Angulo challenged his disqualification through an

administrative appeal to the Police Board of the City of Chicago (Police Board), which upheld the

decision. Navarro-Angulo then filed an action for administrative review in the Circuit Court of

Cook County. The circuit court issued an order affirming the Police Board’s judgment and

Navarro-Angulo now appeals. We affirm the judgment of the Police Board and the circuit court

for the following reasons.

¶3 I. BACKGROUND

¶4 A. Probationary Police Officer Application Procedures

¶5 The application process to become a Chicago police officer is multilayered and involves

various city agencies, including OPSA and CPD. CPD Hiring Process, JoinCPD, (last visited June

17, 2026), https://join.chicagopolice.org/process/ [https://perma.cc/X9QA-ZK8X]. Pre-

employment hiring steps include an application, written exam, drug screen, background

investigation, and other screening measures. Once applicants successfully complete all pre-

employment hiring steps, they receive a formal offer of employment and report to the Chicago

Police Academy for training. Id. After being admitted to the Police Academy, recruits are subject

to an 18-month probationary period. Frequently Asked Questions, JoinCPD, (last visited June 17,

2026), https://join.chicagopolice.org/faq/ [https://perma.cc/P3BP-G4QU]. If an applicant fails any

portion of the hiring process, including the background investigation, OPSA will stop processing

the application and will remove the applicant’s name from the eligibility list. Id.

¶6 Under CPD’s hiring standards, applicants will be removed from the employment eligibility

list if the background investigation uncovers certain types of dishonest or unlawful conduct,

including: (i) the “failure to fully disclose all known information requested [during the background

investigation], whether it is beneficial or prejudicial to the applicant,” (ii) criminal conduct

2 No. 1-25-2229

“demonstrating a reputation or propensity for dishonesty,” including “bribery” and

“eavesdropping”, and (iii) criminal conduct “demonstrating a propensity for violence,” including

“assault; battery, aggravated battery; *** domestic violence; [and] stalking.” Disqualification is

appropriate if there is any evidence that the applicant has engaged in criminal conduct, even if the

applicant was never convicted of a criminal offense.

¶7 B. Appellant’s Application and Disqualification

¶8 In 2023, Navarro-Angulo applied to CPD for a probationary police officer position. During

the application process, OPSA conducted a background investigation of Navarro-Angulo. As part

of the investigation, OPSA collected documents, interviewed Navarro-Angulo and other

individuals, and prepared a report dated May 8, 2024 (the Report). The Report, authored by

investigator James Lynch, describes two main incidents: (1) Navarro-Angulo’s alleged

mistreatment of his ex-girlfriend, S.J., during college in 2012, and (2) his alleged battery of a

woman, L.C.-T., in December 2023.

¶9 According to the Report, in October 2012 Navarro-Angulo allegedly stalked and assaulted

his ex-girlfriend S.J. while they were attending Morton College together. Investigator Lynch relied

on interviews with both Navarro-Angulo and S.J., and a domestic disturbance incident report filed

by the Morton College Police Department on October 3, 2012. In the incident report, a Morton

College police officer described encountering Navarro-Angulo and S.J. engaged in a verbal

altercation. When the officer approached, Navarro-Angulo fled on foot. The officer then spoke

with S.J., who stated that she had broken up with Navarro-Angulo about a month ago and that he

was “controlling” and “could not get over” their breakup. S.J. further stated that Navarro-Angulo

had been attempting to talk to her even though she did not wish to speak to him, and had grabbed

her by the arm, at which point she began walking to the campus police department for help. The

3 No. 1-25-2229

reporting officer later located and spoke to Navarro-Angulo, who was uncooperative and yelled,

“She is my f*** girlfriend! [A]nd is it against the law to speak with my girlfriend?!” Navarro-

Angulo confirmed that he had grabbed S.J. by the arm while attempting to speak to her. The officer

instructed Navarro-Angulo that “there is to be no contact” with S.J. S.J. returned to the police

department approximately five days later and reported that Navarro-Angulo had made multiple

attempts to contact her via telephone, despite the officer’s instruction.

¶ 10 On January 11, 2024, an OPSA investigator interviewed S.J. by telephone. During the

interview, S.J. stated that Navarro-Angulo did not understand that “no means no” and had engaged

in stalking behavior towards her. S.J. further stated that Navarro-Angulo displayed “anger issues,”

and had once thrown a chair at her in the cafeteria at Morton College because he was upset that

S.J. would not leave the cafeteria with him.

¶ 11 In October 2012, S.J. applied for an order of protection against Navarro-Angulo in the

Circuit Court of Cook County. The petition for order of protection stated that Navarro-Angulo

harassed S.J. via phone and text, continued to physically follow her around, and grabbed her at

school when she tried to ignore him. The petition also states that Navarro-Angulo would punch

and throw things when angered, and that S.J. was scared that he would harm her. The court granted

the order of protection.

¶ 12 Investigator Lynch also reviewed a police report regarding an alleged incident involving a

different woman, L.C.-T., on December 10, 2023. The report listed Navarro-Angulo’s name, age,

date of birth, and home address. In the report, a Chicago police officer stated that L.C.-T.

approached the officer’s squad car on the street and was bleeding from a gash on her upper lip.

L.C.-T. told the officer that she had been in the apartment of Navarro-Angulo, who she described

as her boyfriend, when he had physically attacked her. L.C.-T. reported that Navarro-Angulo had

4 No.

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