Vasquez v. Village of Posen

CourtDistrict Court, N.D. Illinois
DecidedMarch 25, 2025
Docket1:24-cv-11209
StatusUnknown

This text of Vasquez v. Village of Posen (Vasquez v. Village of Posen) 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
Vasquez v. Village of Posen, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION MARIO VASQUEZ,

Plaintiff, No. 24 C 11209

v. Judge Thomas M. Durkin

VILLAGE OF POSEN, et al.,

Defendants.

MEMORANDUM OPINION AND ORDER Mario Vasquez brings this action against the Village of Posen (“Village”), Village Police Corporal Richard Schall, and Village Police Officers Eduardo Gonzalez, Osvaldo Carmona, and Fernando Arrozal (collectively, “Defendants”) in connection with his arrest and prosecution for obstructing identification. Defendants move to dismiss certain claims under Federal Rule of Civil Procedure 12(b)(6). R. 15. For the following reasons, that motion is granted. Legal Standard A Rule 12(b)(6) motion challenges the “sufficiency of the complaint.” Gunn v. Cont’l Cas. Co., 968 F.3d 802, 806 (7th Cir. 2020). A complaint must provide “a short and plain statement of the claim showing that the pleader is entitled to relief,” Fed. R. Civ. P. 8(a)(2), sufficient to provide defendant with “fair notice” of the claim and the basis for it. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). This standard “demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). While “detailed factual allegations” are not required, “labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. The complaint must “contain sufficient factual matter, accepted as true, to ‘state a claim

to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 570). “Facial plausibility exists ‘when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.’” Thomas v. Neenah Joint Sch. Dist., 74 F.4th 521, 523 (7th Cir. 2023) (quoting Iqbal, 556 U.S. at 678). In applying this standard, the Court accepts all well-pleaded facts as true and draws all reasonable inferences in favor of the non-

moving party. See Hernandez v. Ill. Inst. of Tech., 63 F.4th 661, 666 (7th Cir. 2023). Background On October 9, 2023, Vasquez had a verbal argument with another patron of T’s Oasis in Posen, Illinois. R. 1 ¶¶ 6, 7. Shortly thereafter, someone called 911. Id. ¶ 10. As Vasquez was leaving, he encountered Corporal Schall and Officers Gonzalez, Carmona, and Arrozal, who had just arrived. Id. ¶ 11. While Corporal Schall and Officer Carmona spoke to individuals inside the bar, Officer Gonzalez asked for

Vasquez’s identification, but Vasquez refused. Id. ¶¶ 13–15, 17. When Corporal Schall returned outside, he confirmed that nothing had occurred inside and was prepared to leave. Id. ¶ 19. But upon hearing that Vasquez declined to provide identification, Corporal Schall asked for Vasquez’s identification again. Id. ¶ 20. After Vasquez again refused, Corporal Schall told him he was in custody and instructed Officer Gonzalez to arrest Vasquez for “obstruction with identification.” Id. ¶ 22. Vasquez was placed in handcuffs, transported to the police station, booked, and released a few hours later. Id. ¶¶ 24, 26, 27. Vasquez was charged with obstructing identification, and the charge was stricken off with leave to reinstate on October 30, 2023. Id. ¶¶ 28, 85; R. 25.

Vasquez brings 42 U.S.C. § 1983 claims for false arrest, false imprisonment, and failure to intervene (Counts I through III) and under Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978) (Count IV); a claim for violating Section 6 of the Illinois Constitution (Count V); state tort claims for false imprisonment, false arrest, intrusion on seclusion, and malicious prosecution (Counts VI through IX); and respondeat superior and indemnification claims (Counts X and XI).

Discussion Defendants seek dismissal of the Monell, Illinois Constitution, and state tort claims. In response to the motion to dismiss, Vasquez concedes that his Illinois Constitution claim and state tort claims for false imprisonment and false arrest (Counts V through VII) are time-barred. See R. 23 at 3. Therefore, those claims are dismissed with prejudice, and the Court addresses each of the remaining claims. I. Monell

A government entity can be liable under § 1983 only “when execution of a government’s policy or custom, whether made by its lawmakers or by those whose edicts or acts may fairly be said to represent official policy, inflicts the injury.” Monell, 436 U.S. at 694. To state a Monell claim, Vasquez must plead facts that plausibly suggest that (1) he was deprived of a constitutional right; (2) the deprivation can be traced to some municipal action (i.e., a policy or custom); (3) the policy or custom demonstrates municipal fault (i.e., deliberate indifference); and (4) the municipal action was the moving force behind the violation. Thomas, 74 F.4th at 524. As to the second factor, three types of municipal action support Monell liability: “(1) an express policy that causes a constitutional deprivation when enforced; (2) a widespread

practice that is so permanent and well-settled that it constitutes a custom or practice; or (3) an allegation that the constitutional injury was caused by a person with final policymaking authority.” Id. (citation omitted). Vasquez alleges that the Village failed to “properly hire, train, and supervise” officers; allowed a “code of silence” wherein officers refused to report each other’s misconduct; and failed to investigate complaints of misconduct, tacitly approved of

and covered up unspecified violations of citizens’ constitutional rights, and failed to establish “appropriate policies and procedures” to correct that misconduct. R. 1 ¶¶ 54(a)–(k). These generic allegations are insufficient to state a claim. Vasquez does not allege what sort of training the Village failed to provide, or in what respect the hiring or supervision of officers was deficient. Nor does he offer facts linking any failure to properly hire, train, or supervise to his injuries. See Prince v. Garcia, No. 22-CV- 05703, 2024 WL 4368130, at *10 (N.D. Ill. Sept. 30, 2024) (dismissing failure-to-train

Monell claim where plaintiff did not define what training the Village failed to provide or plead facts linking that failure to his injuries). Similarly, standing alone, the allegation that the officers who arrested Vasquez did not stop each other from violating his constitutional rights does not plausibly suggest a widespread practice of ignoring police misconduct or a code of silence among the entire Village Police Department. See Jackson v. Vill. of Just., No. 17-CV-07739, 2020 WL 1530734, at *4 (N.D. Ill. Mar. 31, 2020) (allegation that officers in plaintiff’s case helped cover up each other’s wrongdoing was not enough to plausibly allege code of silence); see also Hutton v. City of Chicago, No. 20-CV-03997, 2021 WL 809731, at *4 (N.D. Ill. Mar. 3,

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

Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Vincent v. Williams
664 N.E.2d 650 (Appellate Court of Illinois, 1996)
Ferguson v. City of Chicago
820 N.E.2d 455 (Illinois Supreme Court, 2004)
Carlton Gunn v. Continental Casualty Company
968 F.3d 802 (Seventh Circuit, 2020)
Ronald Fosnight v. Robert Jones
41 F.4th 916 (Seventh Circuit, 2022)
Omar Hernandez v. Illinois Institute of Technology
63 F.4th 661 (Seventh Circuit, 2023)
Sarah Thomas v. Neenah Joint School District
74 F.4th 521 (Seventh Circuit, 2023)
Terrell Esco v. City of Chicago
107 F.4th 673 (Seventh Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
Vasquez v. Village of Posen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vasquez-v-village-of-posen-ilnd-2025.