Smith v. City of Chicago

2026 IL App (1st) 242516-U
CourtAppellate Court of Illinois
DecidedMarch 27, 2026
Docket1-24-2516
StatusUnpublished

This text of 2026 IL App (1st) 242516-U (Smith 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
Smith v. City of Chicago, 2026 IL App (1st) 242516-U (Ill. Ct. App. 2026).

Opinion

2026 IL App (1st) 242516-U No. 1-24-2516

SIXTH DIVISION March 27, 2026

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 JUDICIAL DISTRICT ____________________________________________________________________________

CHET SMITH, ) Appeal from the Circuit Court ) of Cook County, Illinois. Plaintiff-Appellant, ) ) v. ) No. 22 L 6421 ) CITY OF CHICAGO, ) ) The Honorable Defendant-Appellee. ) Jerry A. Esrig, ) Judge Presiding. ____________________________________________________________________________

JUSTICE PUCINSKI delivered the judgment of the court. Justices Hyman and Gamrath concurred in the judgment.

ORDER

¶1 Held: We affirm the trial court’s judgment where it (1) dismissed plaintiff’s complaint with prejudice because his claims were barred by res judicata and untimely filed, and (2) denied plaintiff’s motion for a default judgment.

¶2 Plaintiff Chet Smith appeals pro se from the trial court’s dismissal of his complaint alleging

police misconduct related to his arrest, and subsequent “cover up” of the misconduct. On appeal,

plaintiff contends that the trial court erred in dismissing his complaint because res judicata did not

apply to his claims where a related federal suit was dismissed for lack of jurisdiction and the statute

of limitations had not yet lapsed because he filed the circuit court complaint within a year of the No. 1-24-2516

dismissal of his federal complaint. He also argues that the trial court erred in vacating a default

judgment entered against defendant, the City of Chicago. For the following reasons, we affirm.

¶3 I. BACKGROUND

¶4 The following facts are adduced from, inter alia, plaintiff’s June 18, 2024, pro se second

amended complaint, and the pro se federal complaints and dismissal orders attached to defendant’s

motion to dismiss.

¶5 On September 8, 2018, plaintiff was arrested by police officers in Lansing, Illinois, after

an investigation related to aggravated battery with a firearm. 1 According to plaintiff, the officers

tracked his cellular telephone without obtaining a warrant to do so. The record reflects that plaintiff

was arrested in Lansing, Illinois, but he directed his contentions at the Chicago Police Department

primarily. Plaintiff subsequently requested that the Chicago Office of Police Accountability

(COPA) investigate his criminal case, but they closed his investigation on August 19, 2020.

¶6 Plaintiff filed a pro se federal complaint on December 29, 2020, against defendant, COPA,

and several other individually named defendants, arguing that the officers tracked him illegally

and entered into a conspiracy with COPA to “cover up” the wrongdoing in violation of the Civil

Rights Act (42 U.S.C. § 1983 (2018)). He further contended that he was discriminated against due

to his race, and COPA’s actions in “turn[ing] a blind eye” to the misconduct resulted in a

“deprivation of [plaintiff’s] federally protected rights.” Plaintiff filed a separate federal suit

directed at the unlawful use of the cell site simulator device, which is not in the record on appeal.

During the pendency of these suits, plaintiff filed a FOIA request to the Chicago Office of the

1 According to records from the Illinois Department of Corrections (IDOC), plaintiff was convicted of aggravated battery and sentenced to 10 years’ imprisonment in 2024. See People v. Castillo, 2022 IL 127894, ¶ 40 (“Courts frequently take judicial notice of public documents, including records from the IDOC.”). -2- No. 1-24-2516

Inspector General (OIG) regarding the COPA investigation on March 26, 2021. His request was

denied on April 2, 2021.

¶7 On June 15, 2021, the federal district court entered a final judgment dismissing plaintiff’s

complaint “for failure to state a claim.” The court found that plaintiff did not identify “a

constitutional right that was violated by the alleged failure to investigate his complaint.”

Additionally, plaintiff did not allege facts which established that the COPA investigation affected

the underlying police investigation or that COPA discriminated against him due to his race;

accordingly, he did not state a § 1983 claim because his allegations against defendant and COPA

were conclusory. The court also concluded that COPA’s actions did not prevent him from pursuing

legal remedies, especially since he filed a complaint directed at his allegedly unconstitutional

seizure. The court dismissed plaintiff’s claim that COPA investigators “actively participated in

prolonging his detention” without prejudice, so that he could raise the claim in his other federal

suit. Otherwise, the court dismissed the rest of plaintiff’s allegations with prejudice.

¶8 Plaintiff filed another pro se federal complaint under § 1983 on June 30, 2021, naming

defendant, the OIG Staff, and another set of individual defendants employed by the OIG. In this

complaint, plaintiff contended that the OIG ignored the CPD & COPA misconduct. Plaintiff

alleged that OIG hampered his investigation as part of the conspiracy and committed “misprision

of felony” in actively concealing the misdeeds. He further contended that OIG discriminated

against him due to his race, committed a Freedom of Information Act (FOIA) violation, and did

not adequately train its employees.

¶9 On July 23, 2021, the federal district court dismissed plaintiff’s second § 1983 complaint

as frivolous and for failure to state a claim for which relief could be granted. The court found that

plaintiff’s contentions relied “largely on legal conclusions and lack[ed] context” and detailed the

-3- No. 1-24-2516

history of plaintiff’s other federal complaints regarding the same basic issues. It noted that

plaintiff’s allegations were “for all practical purposes” a duplicate of prior allegations in his 2020

federal complaint with different defendants named. In addressing plaintiff’s claim of a “purported

FOIA violation,” the court noted that such a claim did not arise under the Constitution or federal

law, but rather arose under Illinois law, and thus did not “provide a basis for a claim under section

1983.”

¶ 10 Plaintiff filed a pro se complaint in the circuit court of Cook County on July 10, 2022,

against defendant, COPA, OIG, and the “IPRA.” He contended that a Chicago police detective

“fabricate[d] police reports” and made an “illegal arrest” in Lansing, Illinois related to the

improper use of a “cell-site-simulator” tracking device. He argued that he gave COPA, OIG, and

the other defendants “ample documents” to prove that the Chicago Police Department committed

the misconduct but they provided him with “false and misleading information” and did not

investigate the matter.

¶ 11 On August 23, 2022, plaintiff filed a pro se amended complaint wherein he alleged

additional facts that the detective fabricated police reports to claim that he obtained probable cause

to seize plaintiff, and another officer “illegally deployed a cell-site simulator” to track plaintiff’s

cellular telephone. Defendant, along with COPA, OIG, and “IPRA,” did not respond to plaintiff’s

complaints or provided him with false information.

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Cite This Page — Counsel Stack

Bluebook (online)
2026 IL App (1st) 242516-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-city-of-chicago-illappct-2026.