IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

William Richard, et al., 

 Plaintiffs,

 v.

JB Pritzker and Rob Jeffreys, in their official 

capacities, 

 Defendants. 

No. 20 C 2093

Honorable Steven C. Seeger

 

NOTICE OF VOLUNTARY DISMISSAL

Plaintiffs move to voluntarily dismiss this action without prejudice in compliance with 

the terms of the executed settlement agreement. In support of this voluntary dismissal, the 

Plaintiffs state as follows: 

1. Plaintiffs filed this lawsuit on April 2, 2020, alleging that prison settings “pose a 

particular risk of spreading the COVID-19, with catastrophic consequences not just to the 

prisoners and staff, but also to their communities and the hospitals that serve them.” Plaintiffs’ 

complaint further alleged that the Illinois Department of Corrections “continue[d] to house 

thousands of elderly disabled and medically vulnerable prisoners who could be released, many 

of whom are approaching their release dates and have homes in which they could safely 

quarantine.” The complaint described the specific release mechanisms IDOC officials had at 

their disposal, but failed to implement in the face of the pandemic. The complaint further 

alleged that these failures violated the Plaintiffs’ rights pursuant to the Eighth and Fourteenth 

Amendments to the U.S. Constitution and the Americans with Disabilities Act. 

2. On April 10, 2020, the Court denied the Plaintiffs’ requests for emergency relief 

and for class certification. (Doc 38). Plaintiffs filed an amended complaint on May 20, 2020. 

(Doc. 48). Shortly thereafter, and before defendants filed a responsive pleading, the parties 

Case: 1:20-cv-02093 Document #: 92 Filed: 03/23/21 Page 1 of 4 PageID #:933
began settlement talks in an effort to resolve this lawsuit without further litigation. After almost 

a year of negotiations, the Parties have reached a settlement agreement that includes the 

following terms: 

a. “In connection with efforts to reduce the risk of COVID-19 in Illinois prisons, 

Defendants have been and will continue to cause the IDOC to identify and 

evaluate medically vulnerable prisoners for release through legally available 

mechanisms.” Additionally, for people in custody within nine months of their 

release date and who are statutorily eligible for earned discretionary 

sentencing credit (EDSC),1 the IDOC will award 60 days of EDSC to those 

with a low risk level and 30 days of EDSC credit to those with a medium risk 

level. The IDOC will use its best efforts to process these awards within the 

next thirty days. 

b. The IDOC will provide expedited reviews for the named Plaintiffs who are 

statutorily eligible for release mechanisms.

c. The IDOC will train the Assistant Wardens of Operations and Programs, 

Health Care Unit Administrators, and ADA Coordinators at all facilities on 

the Americans with Disabilities Act and on providing COVID-19 related 

reasonable accommodations to medically vulnerable people with disabilities. 

d. Unless extended by the Parties, the Agreement will terminate on July 1, 2021 

and the Defendants will pay the Plaintiffs’ attorneys’ fees. 

e. The named Plaintiffs released the IDOC from all injunctive claims that 

accrued prior to March 12, 2021. 

1 Illinois State Law and Administrative Directives set forth the eligibility requirements for EDSC. See 730 ILCS 

5/3-6-3

Case: 1:20-cv-02093 Document #: 92 Filed: 03/23/21 Page 2 of 4 PageID #:934
Consistent with the terms of the above referenced settlement agreement, the Plaintiffs 

move this Honorable Court to dismiss this case without prejudice. Within five business days of 

the Department’s submittal of a payment voucher for attorneys’ fees to the Comptroller, the 

Plaintiffs will move to dismiss this action with prejudice. 

Respectfully submitted,

s/Sheila A. Bedi 

Sheila A. Bedi

Sheila A. Bedi

Community Justice Civil Rights Clinic

Northwestern Pritzker School of Law

375 East Chicago Avenue

Chicago, IL 60611

(312) 503-2492

sheila.bedi@law.northwestern.edu

Vanessa del Valle 

Roderick and Solange MacArthur Justice 

Center 

Northwestern Pritzker School of Law 

375 East Chicago Avenue

Chicago, IL 60611 

(312) 503-5932 

vanessa.delvalle@law.northwestern.edu

Jennifer Soble

Illinois Prison Project

53 W. Jackson, Suite 1056

Chicago, IL 60616

(312) 324-4465

jennifer@illinoisprisonproject.org

Alan Mills

Uptown People’s Law Center

4413 N. Sheridan

Chicago, IL 60640

(773) 769-1411

alan@uplcchicago.org

Counsel for Plaintiffs

Sarah Grady

Loevy & Loevy

311 North Aberdeen St., 3rd Floor

Chicago, IL 60607

(312) 243-5900

sarah@loevy.com

Amanda Antholt

Equip for Equality

20 N. Michigan Ave, Suite 300

Chicago, IL 60602

(312) 341-0022

amanda@equipforequality.org

Carolyn E. Shapiro

565 W. Adams

Chicago, Illinois 60661

Case: 1:20-cv-02093 Document #: 92 Filed: 03/23/21 Page 3 of 4 PageID #:935
CERTIFICATE OF SERVICE

The undersigned, an attorney, certifies that she filed the foregoing document via the 

Court’s CM/ECF system on March 23, 2021. 

/s/ Sheila A. Bedi 

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