42 U.S.C. § 1983-Protection from an Inmate

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7^th Circuit Court of Appeals

Case Name: Cristian Ramos v. Krzystof Piech

Case No.: 22-1628

Officials: Easterbrook, Hamilton, and Kirsch, Circuit Judges.

Focus: 42 U.S.C. § 1983-Protection from an Inmate

In 2017, Ramos settled two lawsuits he had brought against Cook County Jail correctional officers under 42 U.S.C. § 1983 alleging a failure to protect Ramos from another inmate and use of excessive force. The settlement agreements contained an identical 262-word sentence—labeled a general release—that released the County and its employees from all claims. Less than a year later, Ramos filed another § 1983 lawsuit against two Cook County police officers based on a 2016 arrest that occurred after the events that lead to the first two lawsuits but prior to the execution of the settlement agreements. Was the scope of the 2017 release broad enough to encompass Ramos’s new lawsuit? The 262-word sentence unambiguously released Cook County from “any and all” claims he had against it, “including but not limited to” the claims arising out of the Jones and Gradowski cases The district court’s grant of summary judgment to the defendants stands

Affirmed.

Decided 12/20/22

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