Shott v. County of McHenry, Illinois

CourtDistrict Court, N.D. Illinois
DecidedOctober 20, 2022
Docket3:22-cv-50075
StatusUnknown

This text of Shott v. County of McHenry, Illinois (Shott v. County of McHenry, Illinois) 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
Shott v. County of McHenry, Illinois, (N.D. Ill. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS WESTERN DIVISION

SUSAN SHOTT,

Plaintiff, Case No. 3:22-cv-50075 v. Honorable Iain D. Johnston COUNTY OF MCHENRY, ILLINOIS, CAITLYN MENEELY, JOHN SOSNOWSKI JR., JENNIFER ASPLUND, CAROLYN DECMAN, JANELLE CARLSON, PAIGE DELFINO, KAITLYN KONZAK, ANASTASIA WARD, PETER KENNEDY, KARA PLONCZYNSKI, and MARYELLEN HOWELL

Defendants.

MEMORANDUM OPINION AND ORDER Before the court is Defendants’ motion to stay Plaintiff’s federal claims pending the resolution of criminal proceedings that run parallel to this case, as well as Defendants’ 12(b)(6) motion to dismiss. Dkt. 14. For the following reasons, the Court grants Defendants’ request for a stay, and denies the motion to dismiss without prejudice to renew it when the stay is lifted.

I. BACKGROUND Plaintiff, Susan Shott, filed suit against McHenry County, seven animal control officers and four McHenry County Sheriff Deputies (Sheriff Deputies). Plaintiff’s complaint has seven counts. Counts I–V allege Fourth Amendment violations brought under 42 U.S.C. § 1983 for unlawful entry, search, seizure, deprivation of property, false arrest, and failure to intervene. In Count VI, Shott brings a claim for intentional infliction of emotional distress and bodily injury against the individual

defendants. Count VII seeks recovery against McHenry County for the actions of the individual defendants in Counts I–V based on the Supreme Court’s holding in Monell v. Dep’t of Social Servs. of the City of New York, 436 U.S. 658 (1978). The claims arise out of the following series of events.1 Susan Shott fell behind on her mortgage payments for the home she lived at in Harvard, Illinois, and on October 30, 2019 the bank foreclosed on her home. Dkt. 15-1, Exh. 2. That same day

an order for eviction was entered in McHenry County. Id. On November 20, 2019, a McHenry County circuit judge granted Shott’s motion to stay possession of the property through December 14, 2019. Dkt 15-1, Exh. 3. Following the order, Shott made private arrangements with the bank to delay her eviction until March 3, 2020, which was done “purely out of courtesy” by the bank. Dkt. 20-1, at 6. On March 4, 2020, Shott requested “a very small extension” until March 8, 2020, to finish moving out, the bank granted this extension. Dkt 20-1, at 8–9.

On March 9, 2020, McHenry Sheriff Deputies arrived at Susan Shott’s home in Harvard, Illinois to enforce an eviction order entered by the McHenry Circuit Court. Shott alleges that the Sheriff Deputies’ arrival was unexpected because she was not informed that she would be evicted on March 9th. Compl. ¶ 29; Dkt. 20 ¶ 5. Shott alleges that Defendants unlawfully entered and searched her fenced yard, attached

1 These facts are taken from Plaintiff’s complaint and Exhibits in the record. garage, and home. Compl. ¶ 38. Stemming from the search and entry on the property, Defendants seized her dogs, her pet snakes, and the body of a dog that had been deceased for two-weeks. Id. Shott asserts that this was done without a

warrant, probable cause, and without her consent. Id. Shott further claims that she was unlawfully deprived of her property in two ways. First, when Defendant Kennedy, as the McHenry Animal Control veterinarian, “lied about the condition” of her pets and “fabricated medical issues that they did not have” to justify euthanizing three dogs and two snakes. Compl. ¶ 86. And second, when Defendants allegedly failed to properly enforce the eviction and prevented their own movers

from removing Shott’s property from the home. Compl. ¶ 54; Compl. at 32–33. Before leaving the property, Defendants issued Shott 32 criminal citations for animal cruelty and/or animal neglect. These criminal charges remain pending in McHenry County. 2022CM000170. Shott alleges these animal abuse/neglect charges are false and were filed against her in retaliation for filing this federal suit. Compl. ¶¶ 68–73; Dkt. 20, at 6–7. II. MOTION TO STAY

Defendants argue that this Court should abstain from proceeding with this case under the Younger abstention doctrine and should stay this suit until Shott’s state criminal proceedings have concluded. A. LEGAL STANDARD The Younger doctrine directs federal courts to abstain from interfering with ongoing state criminal proceedings. The state proceedings must (1) be judicial in nature, (2) implicate important state interests, and (3) offer an adequate opportunity for review of constitutional claims. FreeEats.com v. Indiana, 502 F.3d 590, 596 (7th Cir. 2007); Younger v. Harris, 401 U.S. 37, 53 (1971). State

procedures afford a plaintiff an adequate opportunity for review of constitutional claims. FreeEats.com, 502 F.3d at 598. However, Younger abstention is improper when the pending state proceeding was motivated by a desire to harass or is conducted in bad faith. Id. at 597. When the federal suit is filed first, the court also considers the progress of the federal action before deciding whether abstention is appropriate. Forty One

News, Inc. v. County of Lake, 491 F.3d 663, 666 (7th Cir. 2006). The district court must abstain if no meaningful progress has been made in federal court on the merits. Id. When Younger abstention is required, “the District Court has no discretion to dismiss rather than to stay claims for monetary relief that cannot be redressed in the state proceeding.” Deakins v. Monaghan, 484 U.S. 193, 202 (1988); Gakuba v. O’Brien, 711 F.3d 751, 753 (7th Cir. 2013) (dismissing plaintiff’s civil-

rights claims was improper because the claims had the possibility of becoming time barred at the conclusion of the state proceedings); see also Nelson v. Murphy, 44 F.3d 497, 503 (7th Cir. 1995). A stay allows the state case to go forward without interference from the federal proceeding, while assuming jurisdiction where it properly exists. Simpson v. Rowan, 73 F.3d 134, 139 (7th Cir. 1995) (citing Deakins, 484 U.S. at 202–03). B. ANALYSIS Defendants argue that each of the Younger criteria have been met, so the Court should invoke the doctrine and abstain from hearing Shott’s federal

claims. The Court agrees. Shott’s state criminal proceeding is, in its plain meaning, judicial in nature. Second, the criminal proceeding implicates important state interests. McHenry County and the State of Illinois have an inherent interest in enforcing their laws against animal cruelty, which the state has deemed to be socially harmful conduct. See Younger, 401 U.S. at 52. The final Younger requirement is for Shott to have adequate opportunity to

raise her constitutional claims and have these claims reviewed. Defendants claim that Shott “has the full panoply of criminal trial procedure available to her…”. Def. Memo. in Support, Dkt. 15, at 3. There is no indication that Shott’s state criminal proceeding will prevent her from litigating the issues raised in her complaint at trial or on appeal. All of Shott’s federal claims arise from the events that occurred during her eviction on March 9, 2020, which overlaps with her state criminal charges. So, the conduct she alleges was unlawful in her federal

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Deakins v. Monaghan
484 U.S. 193 (Supreme Court, 1988)
Robert Simpson v. Tim Rowan
73 F.3d 134 (Seventh Circuit, 1995)
Zena D. Crenshaw v. The Supreme Court of Indiana
170 F.3d 725 (Seventh Circuit, 1999)
Peter Gakuba v. Charles O'Brien
711 F.3d 751 (Seventh Circuit, 2013)
Freeeats. Com, Inc. v. Indiana
502 F.3d 590 (Seventh Circuit, 2007)

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Shott v. County of McHenry, Illinois, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shott-v-county-of-mchenry-illinois-ilnd-2022.