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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

JOHN DOE, )

)

PLAINTIFF, )

) Case No.: 20-cv-4065

vs. )

)

CITY OF CHICAGO and FIREFIGHTER )

WILLIAM REGAN, )

)

DEFENDANTS. )

COMPLAINT AT LAW

NOW COMES the Plaintiff, JOHN DOE, by and through his attorneys, Blake Horwitz, 

Esq., and Jeffrey C. Grossich, Esq., of The Blake Horwitz Law Firm, Ltd., and pursuant to this 

Complaint at Law against the above-named Defendants, CITY OF CHICAGO and 

FIREFIGHTER WILLIAM REGAN, states as follows:

I. JURISDICTION AND VENUE

1. The jurisdiction of this Court is invoked pursuant to the Civil Rights Act, 42 U.S.C. 

§ 1983; the Judicial Code, 28 U.S.C. § 1331 and § 1343(a); the Constitution of the United States; 

and this Court’s supplementary jurisdiction powers.

2. Venue is proper pursuant to 28 U.S.C. § 1391(b), as all or some of the parties reside 

in this District and the events giving rise to the claims occurred in this District.

II. PARTIES

3. PLAINTIFF JOHN DOE (hereinafter “PLAINTIFF”) is a resident of Illinois and a 

citizen of the United States.

4. PLAINTIFF is Black.

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5. DEFENDANT FIREFIGHTER WILLIAM REGAN (“DEFENDANT REGAN”) 

was at all times material and relevant hereto employed by and acting on behalf of DEFENDANT 

CITY OF CHICAGO.

6. DEFENDANT REGAN is Caucasian.

7. DEFENDANT CITY OF CHICAGO is a duly incorporated municipal corporation 

and is the employer and principal of DEFENDANT REGAN. At all times material to this 

Complaint, DEFENDANT REGAN was acting under color of state law, ordinance and/or 

regulation, statutes, custom and usage of DEFENDANT CITY OF CHICAGO.

III. FACTS

8. In July 2018, PLAINTIFF was enrolled in a paramedic training program at 

Malcolm X College.

9. As part of the paramedic training program, PLAINTIFF was assigned to participate 

in “ride-alongs” with the Chicago Fire Department.

10. These “ride-alongs” consisted, in part, of PLAINTIFF spending the night at a 

Chicago Fire Department firehouse.

11. PLAINTIFF participated in “ride-alongs” with the Chicago Fire Department for the 

purpose of learning how to be a paramedic.

12. PLAINTIFF was an intern of the Chicago Fire Department.

13. On July 20, 2018, PLAINTIFF was assigned to perform a “ride-along” at Chicago 

Fire Department Engine 126/Truck 49, located at 7313 South Kingston Avenue, Chicago, Illinois 

60649.

14. On July 20, 2018, at approximately 6:30 p.m., PLAINTIFF was present at Chicago 

Fire Department Engine 126/Truck 49.

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15. On July 20, 2018, at approximately 6:30 p.m., DEFENDANT REGAN was present 

at Chicago Fire Department 126/Truck 49.

16. On July 20, 2018, at approximately 6:30 p.m., PLAINTIFF and DEFENDANT 

REGAN were sitting next to each other at the dinner table at Chicago Fire Department 126/Truck 

49.

17. DEFENDANT REGAN asked PLAINTIFF if PLAINTIFF wanted to get in the 

shower with DEFENDANT REGAN.

18. DEFENDANT REGAN told PLAINTIFF there was a pool in the basement of 

Chicago Fire Department 126/Truck 49.

19. DEFENDANT REGAN said to PLAINTIFF, “I can teach you how to swim naked.”

20. DEFENDANT REGAN said to PLAINTIFF, “I can teach you how to play Marco 

Polo naked.”

21. DEFENDANT REGAN put his hand on PLAINTIFF’S left leg.

22. DEFENDANT REGAN put his hand on PLAINTIFF’S genitals.

23. DEFENDANT REGAN grabbed PLAINTIFF’S genitals.

24. PLAINTIFF did not consent to being touched by DEFENDANT REGAN.

25. When DEFENDANT REGAN grabbed PLAINTIFF’S genitals, PLAINTIFF’S 

movement was restricted.

26. When DEFENDANT REGAN grabbed PLAINTIFF’S genitals, PLAINTIFF was 

not free to leave.

27. After DEFENDANT REGAN grabbed PLAINTIFF’S genitals, PLAINTIFF 

informed other Chicago Fire Department personnel at Chicago Fire Department Engine 126/Truck 

49.

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28. In response, at least four Chicago Fire Department Battalion Chiefs arrived at 

Chicago Fire Department Engine 126/Truck 49.

29. PLAINTIFF told the Chicago Fire Department Battalion Chiefs and other personnel 

that he wanted to report the conduct of DEFENDANT REGAN.

30. Multiple Chicago Fire Department Battalion Chiefs and other personnel tried to 

threaten and coerce PLAINTIFF into not reporting the conduct of DEFENDANT REGAN.

31. Chicago Fire Department Battalion Chiefs and other personnel told PLAINTIFF, 

“It was just firehouse horseplay.”

32. Chicago Fire Department Battalion Chief Dan Mullaney told PLAINTIFF, “He 

[DEFENDANT REGAN] was just playing around.”

33. Chicago Fire Department Battalion Chiefs and other personnel told PLAINTIFF 

that DEFENDANT REGAN wanted to apologize.

34. PLAINTIFF told the Chicago Fire Department Battalion Chiefs and other personnel 

that he wanted to call the police.

35. Multiple Chicago Fire Department Battalion Chiefs and other personnel tried to 

threaten and coerce PLAINTIFF into not calling the police.

36. PLAINTIFF called the police and the police arrived.

37. After the police arrived, multiple Chicago Fire Department Battalion Chiefs and 

other personnel tried to discredit PLAINTIFF.

38. A Chicago Fire Department Captain, referring to PLAINTIFF, told police, “This 

motherfucker doesn’t know what he’s talking about.”

39. Multiple Chicago Fire Department Battalion Chiefs and other personnel lied to the 

police.

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40. Multiple Chicago Fire Department Battalion Chiefs and other personnel actively 

impeded a police investigation.

41. Multiple Chicago Fire Department Battalion Chiefs and other personnel actively 

tried to cover up for the actions of DEFENDANT REGAN.

42. Multiple Chicago Fire Department Battalion Chiefs and other personnel told police 

that they did not know who allegedly touched PLAINTIFF. This was false, as the Battalion Chiefs 

and other personnel knew that DEFENDANT REGAN had touched PLAINTIFF.

43. On July 20, 2018, while PLAINTIFF was present at Chicago Fire Department 

Engine 126/Truck 49, PLAINTIFF was being taught by DEFENDANT REGAN.

44. On July 20, 2018, while PLAINTIFF was present at Chicago Fire Department 

Engine 126/Truck 49, PLAINTIFF was subordinate to DEFENDANT REGAN.

45. On July 20, 2018, while PLAINTIFF was present at Chicago Fire Department 

Engine 126/Truck 49, PLAINTIFF was in a subordinate position to DEFENDANT REGAN.

46. On July 20, 2018, while PLAINTIFF was present at Chicago Fire Department 

Engine 126/Truck 49, PLAINTIFF had to follow instructions given to him by DEFENDANT 

REGAN.

47. Alternatively, DEFENDANT REGAN’S touching of PLAINTIFF was not a 

personal matter.

48. Alternatively, DEFENDANT REGAN’S touching of PLAINTIFF was not 

motivated by personal animosity on the part of DEFENDANT REGAN.

49. Alternatively, DEFENDANT REGAN’S touching of PLAINTIFF was not for 

DEFENDANT REGAN’S sexual gratification.

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50. Alternatively, DEFENDANT REGAN grabbed PLAINTIFF’S genitals for, inter 

alia, the following reasons: to assert DEFENDANT REGAN’S authority, to enforce the Chicago 

Fire Department chain-of-command, to initiate PLAINTIFF into Chicago Fire Department 

firehouse culture, to test PLAINTIFF’S willingness to be part of the firehouse group dynamic, and 

to test PLAINTIFF’S willingness to be a team player.

51. Alternatively, there exists a culture of hazing and horseplay within the Chicago Fire 

Department.

52. Alternatively, the culture of hazing and horseplay within the Chicago Fire 

Department is implicitly approved of, promoted, and encouraged by policymakers, supervisors, 

and management within the Chicago Fire Department.

53. Alternatively, by making sexual comments to PLAINTIFF and grabbing 

PLAINTIFF’S genitals, DEFENDANT REGAN was acting in conformity with and/or reinforcing 

the hazing and horseplay culture within the Chicago Fire Department.

54. Alternatively, DEFENDANT REGAN’S behavior in making sexual comments to 

PLAINTIFF and grabbing PLAINTIFF’S genitals was implicitly and explicitly approved of, 

promoted, and encouraged by policymakers, supervisors, and management within the Chicago Fire 

Department.

COUNT I

Fourth Amendment Unlawful Seizure Pursuant to 42 U.S.C. § 1983

(DEFENDANT REGAN)

55. PLAINTIFF realleges paragraphs 1-54 set forth above.

56. DEFENDANT REGAN violated PLAINTIFF’S clearly established constitutional 

right to be free from unlawful searches and seizures.

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57. The conduct of DEFENDANT REGAN alleged above violated the Fourth 

Amendment to the United States Constitution.

58. The aforementioned actions of DEFENDANT REGAN were the direct and 

proximate cause of the constitutional violations set forth above, and PLAINTIFF suffered 

damages.

WHEREFORE, PLAINTIFF respectfully requests that this Honorable Court enter 

judgment in favor of PLAINTIFF and against DEFENDANT REGAN, and award compensatory 

damages, punitive damages, court costs, attorneys’ fees, and such other relief that this Honorable 

Court deems just and equitable.

COUNT II

Indemnification Claim Pursuant to 745 ILCS 10/9-102

(DEFENDANT CITY OF CHICAGO)

59. PLAINTIFF realleges paragraphs 1-58 set forth above.

60. DEFENDANT CITY OF CHICAGO is the employer of DEFENDANT REGAN.

61. DEFENDANT REGAN, as alleged above, committed the acts under color of law 

in the scope of his employment by DEFENDANT CITY OF CHICAGO.

62. Pursuant to the Illinois Tort Immunity Act, 745 ILCS 10/9-102, DEFENDANT 

CITY OF CHICAGO is liable for any judgments for compensatory damages arising from 

DEFENDANT REGAN’S actions.

WHEREFORE, should DEFENDANT REGAN, in his individual capacity, be found liable 

for any of the alleged counts in this cause, PLAINTIFF demands that, pursuant to 745 ILCS 10/9-

102, DEFENDANT CITY OF CHICAGO pay any judgment obtained against DEFENDANT 

REGAN.

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COUNT III

Monell Claim

(DEFENDANT CITY OF CHICAGO)

63. PLAINTIFF realleges paragraphs 1-58 set forth above.

64. It is the custom, practice, and/or policy of Chicago Fire Department personnel 

and/or their supervisors/agents and/or other employees of the Chicago Fire Department to perform 

the following acts and/or omissions:

a. generate false documentation to cover-up for the misconduct of fellow fire 

department personnel;

b. fabricate documents concerning acts of misconduct that have occurred by 

fellow firefighters;

c. engage in acts of sexual misconduct;

d. engage in the excessive use of force;

e. fail to properly discipline personnel from said fire department who have 

committed acts of sexual misconduct and/or excessive use of force;

f. fail to properly investigate complaints;

g. fail to take proper remedial action against personnel from said fire department 

who have committed acts of sexual misconduct and/or excessive use of force;

h. allow misconduct to occur in various types and severity such that all fire 

department personnel believe that they can engage in sexual misconduct and/or 

excessive force without repercussions and/or significant repercussions;

i. fail to provide adequate sanctions/discipline to fire department personnel who 

commit acts of sexual misconduct and/or excessive force; and

65. This practice and/or custom, as alleged above, has gone unchecked and has been 

allowed to exist in the Chicago Fire Department for a significant period of time, so much so that 

fire department personnel recognize that they will not be punished for committing said acts. In 

fact, said acts are either permitted or quietly consented to by superiors of the Chicago Fire 

Department in order to permit said conduct to reoccur.

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66. A code of silence exists among Chicago Fire Department personnel. This code of 

silence obstructs the legal process (preventing the free flow of honest information with regard to 

acts of misconduct). This code of silence contributes to the generation of secrets regarding 

misconduct within the Chicago Fire Department.

67. Since 2008, the Chicago Fire Department has paid out nearly $92 million in 

workplace discrimination lawsuits.

68. On November 1, 2011, then-Captain Mark Altman of the Chicago Fire Department 

swore at and then violently threw to the ground twice Chicago Police Officer and marine diver 

Joseph Smith during a water rescue in the Chicago River.

69. A federal jury found Captain Altman liable for these acts on October 24, 2014.

70. A judgment of $1,331,779.15 was entered against Captain Altman.

71. That jury found that Captain Altman should pay to Mr. Smith $5,000.00 in punitive 

damages.

72. Captain Altman paid the punitive damages award.

73. Mr. Smith settled with the City of Chicago for $1,122,490.00 in compensatory 

damages.

74. Mr. Smith’s attorneys were paid $479,334.03 in attorneys’ fees by the City of 

Chicago.

75. Captain Altman was never demoted in connection with the injuries he inflicted onto 

Joseph Smith.

76. Captain Altman was never disciplined in connection with the injuries he inflicted 

onto Joseph Smith.

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77. After Captain Altman paid the punitive damages award, he was then promoted 

within the Chicago Fire Department.

78. As a result of the injuries that Mr. Smith sustained from the use of excessive force 

by Captain Altman, Mr. Smith underwent two surgeries, one to his neck and one to his back.

79. Mr. Smith has returned to work on a permanent light-duty restriction due to the 

injuries that were inflicted upon him by Captain Altman.

80. Jennifer Manzella, a civilian, engaged in sexual acts for money with Chicago Fire 

Department firefighters at Engine 11, located at 5343 North Cumberland Avenue, Chicago, 

Illinois.

81. On January 20, 2018, approximately a dozen Chicago Fire Department firefighters 

were disciplined for allowing another firefighter to engage in sexual acts at a firehouse on the 

South Side of Chicago.

82. On April 6, 2018, a Chicago Fire Department paramedic was placed on leave 

because he repeatedly masturbated in full view of his coworkers at a firehouse on the South Side 

of Chicago.

83. Chief Raney of the Chicago Fire Department made sexual remarks to and requested 

sexual favors from a female Chicago Fire Department paramedic. Raney demanded a sexual 

relationship from the paramedic, referencing “blow jobs” in his communications with her.

84. Chicago Fire Department firefighter George Olifer sexually harassed a Chicago 

Fire Department paramedic and posted a picture of her in her bra and underwear on Facebook, 

without her consent.

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85. Ambulance Commander George Bedon repeatedly made sexually suggestive 

statements to three separate paramedics of the Chicago Fire Department and physically touched 

and attempted to kiss them without consent.

86. Bedon made sexually suggestive statements to these Chicago Fire Department 

paramedics, including: “What color are your nipples?”, “Do you wear a thong?”, “What kind of 

underwear are you wearing?”, “I can tell what kind of underwear you’re wearing,” that they 

“looked good,” and that they had a “good body.”

87. On November 3, 2017, Eric Heard, who served as a deliveryman for a local delivery 

service, delivered bunker gear to Captain John Jakubec of the Chicago Fire Department. At that 

time, Captain Jakubec grabbed Mr. Heard’s buttocks, struck Mr. Heard on the head, grabbed Mr. 

Heard’s delivery receipt, rubbed it on Captain Jakubec’s genitals, and made sexual noises. Captain 

Jakubec’s coworkers at the Chicago Fire Department lied to Internal Affairs investigators about 

the incident in an attempt to cover up Captain Jakubec’s misconduct.

88. On March 28, 2018, Chicago Fire Department Firefighter John Copeland was 

punched in the face twice by his superior, Chicago Fire Department Lieutenant Leonard Johnson. 

As a result of the incident, Lieutenant Johnson was found guilty of criminal battery in violation of 

720 ILCS 5.0/12-3(A)(1).

89. As a direct and proximate result of the aforementioned acts and omissions by 

DEFENDANT CITY OF CHICAGO, there exists a custom, practice, policy, and/or pattern, either 

implicit or explicit, by DEFENDANT CITY OF CHICAGO, in which Chicago Fire Department 

personnel cover up for the wrongful and/or illegal acts of their colleagues.

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90. Said custom, practice, policy, and/or pattern by DEFENDANT CITY OF 

CHICAGO encourages, endorses, is willfully ignorant to, or otherwise promotes wrongful acts 

such as those committed by DEFENDANT REGAN.

91. As a direct and proximate result of the aforesaid custom, practice, policy, and/or 

pattern, either implicit or explicit, by DEFENDANT CITY OF CHICAGO, PLAINTIFF was 

injured in a personal and pecuniary manner.

WHEREFORE, PLAINTIFF respectfully requests that this Honorable Court enter 

judgment in favor of PLAINTIFF and against DEFENDANT CITY OF CHICAGO, and award 

compensatory damages, punitive damages, court costs, attorneys’ fees, and such other relief that 

this Honorable Court deems just and equitable.

JURY DEMAND

PLAINTIFF demands trial by jury.

Respectfully Submitted,

s/Jeffrey C. Grossich____________

Attorney for Plaintiff

Blake Horwitz, Esq.

Jeffrey C. Grossich, Esq.

The Blake Horwitz Law Firm, Ltd.

111 West Washington Street, Suite 1611

Chicago, Illinois 60602

Phone: (312) 676-2100

Fax: (312) 445-8741

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