Warren v. Will County

CourtDistrict Court, N.D. Illinois
DecidedMarch 19, 2025
Docket1:24-cv-05219
StatusUnknown

This text of Warren v. Will County (Warren v. Will County) 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
Warren v. Will County, (N.D. Ill. 2025).

Opinion

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

DESMOND B. WARREN,

Plaintiff, Case No. 1:24-cv-05219 v. Judge Mary M. Rowland WILL COUNTY, and WILL COUNTY SHERIFF,

Defendants.

MEMORANDUM OPINION AND ORDER Plaintiff Desmond B. Warren has sued Will County and Will County Sheriff (together “Defendants”), alleging violations of Title VII, Section 1983, and Section 1981. For the reasons stated herein, Defendants’ partial motion to dismiss [7] is granted. I. Background The following factual allegations taken from the operative complaint [1] are accepted as true for the purposes of the motion to dismiss. See Lax v. Mayorkas, 20 F.4th 1178, 1181 (7th Cir. 2021). Warren is a Black individual, [1] ¶ 6, who started working at the Will County Sheriff’s (WCS) Office as a deputy sheriff in April 2014, [1] ¶ 11. Warren’s job performance at all relevant times met or exceeded the WCS’s legitimate expectations. [1] ¶ 15. Warren applied for a WCS SWAT team position in September 2020 and WCS told him on October 9, 2020, that he was not selected for the position. [1] ¶¶ 16-18. Warren applied for a position with the Tri County Auto Theft (TCAT) unit in September 2021 and WCS told him later that month that he was not selected for the role. [1] ¶¶ 20-22. Warren applied for a detective position in WCS’s Office in February 2022 and WCS told Warren in March 2022 that he was not selected for the position.

[1] ¶¶ 24-26. Warren applied for another detective position in December 2022 and later that month WCS told him he was not selected for the role. [1] ¶¶ 28-30. Warren alleges that WCS selected less qualified, non-Black individuals for the positions he applied for between September 2020 and December 2022. [1] ¶¶ 19, 23, 27, 31. In April 2023, Warren applied for a role with the WCS SWAT team and WCS selected Warren for the position. [1] ¶¶ 32-33, 36. In September 2023, Warren was

certified as a field training officer (FTO) which allowed him to train new deputies. [1] ¶ 38. WCS assigned non-Black deputies that received the FTO certification at the same time as Warren multiple new officers to train, which allowed those deputies to earn extra pay, but WCS did not assign Warren a new officer to train despite Warren being the most experienced police officer in the group. [1] ¶¶ 40-43. In addition, WCS did not promote Warren to sergeant despite Warren being next on the promotion list between February 7, 2022 and February 7, 2024. [1] ¶¶ 58-63.

On December 7, 2023, Warren filed a charge of race discrimination in violation of Title VII with the Equal Employment Opportunity Commission (EEOC) against Defendants. [1] ¶ 4. On March 26, 2023, Warren received a Notice of Right to Sue in connection with his EEOC charge. [1] ¶ 5. On June 21, 2024, Warren filed this lawsuit against Defendants. Defendants move to dismiss Warren’s race discrimination in violation of Title VII (Count I) and race discrimination in violation of Section 1983 (Count III) claims to the extent they rely on time-barred activity. Defendants also move to dismiss Warren’s retaliation in violation of Section 1983 (Count VI) claim. Standard

“To survive a motion to dismiss under Rule 12(b)(6), the complaint must provide enough factual information to state a claim to relief that is plausible on its face and raise a right to relief above the speculative level.” Haywood v. Massage Envy Franchising, LLC, 887 F.3d 329, 333 (7th Cir. 2018) (quoting Camasta v. Jos. A. Bank Clothiers, Inc., 761 F.3d 732, 736 (7th Cir. 2014)); see also Fed. R. Civ. P. 8(a)(2) (requiring a complaint to contain a “short and plain statement of the claim showing

that the pleader is entitled to relief”). A court deciding a Rule 12(b)(6) motion “construe[s] the complaint in the light most favorable to the plaintiff, accept[s] all well-pleaded facts as true, and draw[s] all reasonable inferences in the plaintiff’s favor.” Lax, 20 F.4th at 1181. However, the court need not accept as true “statements of law or unsupported conclusory factual allegations.” Id. (quoting Bilek v. Fed. Ins. Co., 8 F.4th 581, 586 (7th Cir. 2021)). “While detailed factual allegations are not necessary to survive a motion to dismiss, [the standard] does require ‘more than mere

labels and conclusions or a formulaic recitation of the elements of a cause of action to be considered adequate.’” Sevugan v. Direct Energy Servs., LLC, 931 F.3d 610, 614 (7th Cir. 2019) (quoting Bell v. City of Chicago, 835 F.3d 736, 738 (7th Cir. 2016)). II. Analysis A. Overview In the partial motion to dismiss, Defendants argue that Warren’s Title VII race discrimination (Count I) claim is time barred to the extent it relies on conduct before February 10, 2023, and Warren’s Section 1983 race discrimination (Count III) claim

is time barred to the extent it relies on conduct before June 21, 2022. [7] at 3-5. Defendants also argue that Warren failed to state a claim for First Amendment retaliation. [7] at 5-9. The Court takes Defendants’ arguments in turn. B. Warren’s Title VII race discrimination (Count I) claim is time barred to the extent it relies on conduct before February 10, 2023. Warren filed his charge with the EEOC on December 7, 2023. [1] ¶ 4. Defendants argue that because only discrete discriminatory and retaliatory acts that occurred within 300 days of Warren’s filing date are actionable under Title VII, all discrete acts alleged by Warren that occurred before February 10, 2023, including the denial of his SWAT application in October 2020, the denial of his TCAT application in September 2021, and the denial of both of his detective applications in 2022, are time barred and not actionable for purposes of Warren’s Title VII race discrimination claim. [7] at 3-4. Plaintiff agrees with Defendants’ argument. [14] at 1.1 The Court

grants Defendants’ partial motion to dismiss on this issue. Plaintiff’s Title VII race discrimination claim is dismissed to the extent it relies on conduct occurring before February 10, 2023.

1 Plaintiff asserts that to the extent he agrees certain acts are time barred, he “is allowed to conduct discovery into (and seek admissibility at trial of) such time-barred acts/omissions and relevant surrounding facts/circumstances as background evidence in support of his timely claims.” [14] at 1. The Court declines to address this issue at this time. C. Warren’s Section 1983 race discrimination (Count III) claim is time barred to the extent it relies on conduct before June 21, 2022. Warren filed this lawsuit on June 21, 2024. Defendants argue that because only discrete discriminatory and retaliatory acts that occurred within two years of the filing date are actionable under his Section 1983 claim, all discrete acts alleged by Warren that occurred before June 21, 2022, including the denial of Warren’s SWAT application in October 2020, the denial of his TCAT application in September 2021, and the denial of his detective application in March 2022, are time-barred and not actionable for purposes of Warren’s Section 1983 race discrimination (Count III) claim. [7] at 4-5. Plaintiff agrees with Defendants’ argument. [14] at 1. The Court

grants Defendants’ partial motion to dismiss on this issue.

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Warren v. Will County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/warren-v-will-county-ilnd-2025.