504369_1 

THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

Michael Liggins, ) 

) 

Plaintiff, ) 

) 

v. ) Case No. 20 C 4085 

) 

City of Chicago, Det. Russell ) Judge Rowland 

Egan, and Det. Vincent Alonzo, ) 

) 

Defendants. ) 

LIMITED CONSENT TO ENTRY OF JUDGMENT 

AGAINST DEFENDANT CITY OF CHICAGO 

Defendant City of Chicago, by its attorney, Celia Meza, Corporation Counsel for the City 

of Chicago, hereby stipulates to the following: 

1. Plaintiff Michael Liggins, individually, has filed a Complaint against Defendant 

City of Chicago (“City”) and two individual Chicago Police Department officer defendants, 

Detectives Vincent Alonzo and Russell Egan. Plaintiff’s Complaint includes various claims 

brought under state and federal law. 

2. In the Complaint, Plaintiff claims that the individual officer defendants violated 

his constitutional rights as a result of various policies, practices, and customs of the City. In 

other words, Plaintiff has brought a Monell claim against the City. See Monell v. Department of 

Social Services of City of New York, 436 U.S. 658 (1978). Plaintiff seeks a judgment against the 

City for damages caused by the alleged violation of his rights under the Constitution. 

3. Even if Plaintiff’s constitutional rights were violated as alleged, the City 

specifically denies any such constitutional violation was caused by a person with “final 

policymaking authority,” denies the City has any “policies, customs, or practices” that cause 

Case: 1:20-cv-04085 Document #: 81 Filed: 12/01/21 Page 1 of 5 PageID #:932
 504369_1 

constitutional deprivations, denies it has any widespread deficient or unconstitutional practice 

that is “so permanent and well-settled as to constitute a custom or usage with the force of law,” 

denies it has the requisite degree of culpability therefrom, and denies that any alleged “policy, 

custom, or practice” of the City directly caused the alleged violations that would give rise to 

liability under 42 U.S.C. § 1983. 

4. Without admitting the Monell allegations in the Complaint, the City will consent 

to entry of judgment against the City for compensatory damages and, to the extent allowed by 

the court, reasonable attorney fees pursuant to 42 U.S.C. § 1988, and costs, if the finder of fact in 

this case finds that any of the Individual Officer Defendants, or any former or present employee 

of the City disclosed by Plaintiff no later than thirty (30) days prior to the close of fact discovery 

and whom the Court permits to be included on a jury instruction subject to the conditions set 

forth below, is liable for pretrial detention of Plaintiff without probable cause, as alleged in 

Count 2 of the Complaint and consistent with the Court’s previous ruling on Defendants’ Motion 

to Dismiss (ECF Dkt. 59), or conspiracy to commit pretrial detention without probable cause, or 

failure to intervene in the unconstitutional actions of another for pretrial detention without 

probable cause. The parties agree that the names of the non-defendant current or former 

employees will not appear on the verdict form. Rather, the verdict form will ask the jury to find 

for the City of Chicago, if the jury finds that none of the Defendant or non-defendant current or 

former employees are responsible for the injury, or against the City of Chicago, if the jury finds 

that one or more of the Defendant or non-defendant current or former employees are responsible 

for the injury. 

5. With respect to the individual officer defendants’ assertion of qualified immunity, 

the City will consent to entry of judgment against it for compensatory damages and, to the extent 

Case: 1:20-cv-04085 Document #: 81 Filed: 12/01/21 Page 2 of 5 PageID #:933
 504369_1 

allowed by the Court, reasonable attorney fees pursuant to 42 U.S.C. §1988, and costs, if the 

finder of fact determines that one or more of the individual officer defendants or any former or 

present employee of the City disclosed by Plaintiff no later than thirty (30) days prior to the close 

of fact discovery and whom the Court permits to be included on a jury instruction subject to the 

conditions set forth in paragraph 4, is liable for pretrial detention of Plaintiff without probable 

cause, as alleged in Count 2 of the Complaint and consistent with the Court’s previous ruling on 

Defendants’ Motion to Dismiss (ECF Dkt. 59), or conspiracy to commit pretrial detention 

without probable cause, or failure to intervene in the unconstitutional actions of another for 

pretrial detention without probable cause, even if the individual officer defendants are further 

found to be not liable to Plaintiff because he is entitled to qualified immunity. 

6. For this purpose and in this case only, the City waives its right under Monell not 

to be found liable for damages pursuant to Section 1983 without proof that the City by its 

“policy, custom, or practice,” and with the requisite degree of culpability, caused the alleged 

constitutional violation. As stated herein, if liability for a constitutional violation is found against 

one or more of the individual officer defendants or the City, as in any former or present 

employee of the City disclosed by Plaintiff no later than thirty (30) days prior to the close of fact 

discovery and whom the Court permits to be included on a jury instruction subject to the 

conditions set forth in paragraph 4 and 5 above, the City agrees to accept liability against it for 

compensatory damages and, to the extent allowed by the Court, reasonable attorney fees and 

costs, based solely on that alleged constitutional violation, and not upon any alleged “policy, 

custom, or practice.” The Consent to Entry of Judgment will not apply to liability based on a 

settlement to which the City is not a party, or a non-court procedure, such as arbitration or 

mediation, unless the City agrees to be bound by such proceedings. 

Case: 1:20-cv-04085 Document #: 81 Filed: 12/01/21 Page 3 of 5 PageID #:934
 504369_1 

7. The City does not waive any defense it may have to the claims in this case except 

as specifically stated above. The City also retains the right to move, alter or amend any 

judgment, move for judgment as a matter of law reversing such judgment, appeal, or seek any 

other post-trial relief from such judgment based on any grounds not inconsistent with this 

Consent. The City also retains the right to move for Summary Judgment, to the extent necessary, 

against any and all individuals named by the Plaintiff within 30 days of the close of fact 

discovery, and to otherwise move the Court to dismiss or prevent such individuals named by the 

Plaintiff within 30 days of the close of fact discovery from being included in the jury 

instructions, as described in paragraphs 4, 5 and 6 at the appropriate procedural times, including 

requesting the Court rule on the objections on the basis of whether the evidentiary basis against 

any such former or current employee identified would be sufficient to support a jury finding, by 

a preponderance of the evidence, that the individual violated the Plaintiff’s constitutional rights. 

8. Moreover, any liability must be final, meaning that a finding is either not 

appealed or that finding is appealed and affirmed in a final, non-appealable ruling of the highest 

appellate court to hear the matter, which applies regardless of whether the finding is by summary 

judgment or after a trial on the merits. Likewise, if no underlying constitutional violation is 

found against any of the Defendant officers or any former or present employee of the City 

disclosed by Plaintiff no later than thirty (30) days prior to the close of fact discovery and whom 

the Court permits to be included on a jury instruction, this Court would enter judgment in favor 

of the City on the Monell claim, which applies regardless of whether the finding is by a motion 

for summary judgment, motion for judgment as a matter of law, or after a trial on the merits. 

Case: 1:20-cv-04085 Document #: 81 Filed: 12/01/21 Page 4 of 5 PageID #:935
 504369_1 

 Respectfully submitted, 

Celia Meza 

Corporation Counsel of the City of Chicago 

BY: /s/ Caroline Fronczak 

Deputy Corporation Counsel 

Caroline Fronczak, Deputy Corporation Counsel 

City of Chicago – Department of Law 

Federal Civil Rights Litigation Division 

2 North LaSalle Street, Suite 420 

Chicago, Illinois 60602 

(312) 744-5170 

By: /s/Anthony Becknek 

One of their attorneys 

Lance C. Malina – Special Assistant Corporation Counsel (lcmalina@ktjlaw.com) 

Allen Wall - Special Assistant Corporation Counsel (jawall@ktjlaw.com) 

Anthony G. Becknek - Special Assistant Corporation Counsel (agbeckneck@ktjlaw.com) 

Carrie A. Winteregg - Special Assistant Corporation Counsel (cawinteregg@ktjlaw.com) 

KLEIN, THORPE AND JENKINS, LTD. 

20 North Wacker Drive, Suite 1660 

Chicago, Illinois 60606 

(312) 984-6400 

Michael Liggins, Plaintiff 

By: /s/ Russell R. Ainsworth 

Attorney for Plaintiff

Arthur Loevy (Arthur@loevy.com) 

Jon Loevy (Jon@loevy.com) 

Russell Ainsworth (Russell@loevy.com) 

Roshna Bala Keen (Roshna@loevy.com) 

Loevy & Loevy 

311 N. Aberdeen St., 3rd Floor 

Chicago, IL 60607 

312-243-5900 

Case: 1:20-cv-04085 Document #: 81 Filed: 12/01/21 Page 5 of 5 PageID #:936