A claim of willful and wanton misconduct must demonstrate either an actual intention to harm or a reckless disregard for the safety of others, such as a failure to exercise ordinary care to prevent harm after knowledge of impending danger, or a failure to discover the danger when it could have been discovered by exercise of ordinary care. Plaintiffs' complaint alleged the Board had knowledge male students were likely to commit sexual assaults on female passengers, but failed to support this allegation with any specific facts from which knowledge or propensity could be inferred. Although a reviewing court must take all well pled allegations as true when reviewing a dismissal under section 2-619, it does not have to accept conclusions of fact which are unsupported by specific facts. Plaintiffs' complaint failed to set forth specific facts supporting a claim of willful and wanton misconduct. However, even in the absence of this factual insufficiency, dismissal of count III was mandated under section 4-102.
Plaintiffs misconstrue the holding of that case.
In Cadena, plaintiffs, who were spectators at a public fireworks display, alleged they were injured as a result of the city's failure to provide adequate police services in the form of crowd control. The court held plaintiffs' claim was barred by section 4-102. However, the court distinguished plaintiffs' claim predicated upon the city's failure to provide adequate crowd control from a claim alleging police affirmatively directed spectators to unsafe areas. App.3d at 955-56. In reaching this determination, the court relied upon our Supreme Court's decision in Doe v.