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Class Action-Sovereign Immunity

7th Circuit Court of Appeals

Case Name: T. S. v. County of Cook

Case No.: 21-3303

Officials: Rovner, Brennan, and Scudder, Circuit Judges.

Focus: Class Action-Sovereign Immunity

Twentieth Century Fox Television filmed scenes for the fictional television series Empire at the Cook County Juvenile Temporary Detention Center in 2015. The Center changed its operations to accommodate filming. Those changes resulted in this case.

In this interlocutory appeal, the Seventh Circuit considers whether the Center’s superintendent, Leonard Dixon, is immune from suit under the Illinois State Lawsuit Immunity Act, 745 ILL. C OMP. STAT. 5/1. Because the alleged wrongful conduct arose from decisions Dixon made within the scope of his authority as superintendent, he is entitled to state sovereign immunity. The Seventh Circuit reverses the district court’s denial of summary judgment and dismiss this case.

Reversed and Remanded.

Decided 05/15/23

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