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Gonzalez v. McHenry County
40 F.4th 824 (7th Cir. 2022)

In Gonzalez v. McHenry County, the court (Manion/Hamilton/Brennan, with Manion writing) affirmed summary judgment against the estate of a man who was detained at the McHenry County Jail after being admitted despite a panoply of serious medical issues. (The man died after leaving the Jail while in IDOC custody.) The estate had brought a Monell claim against the Sheriff, arguing that it had a policy of admitting anyone into the jail regardless of whether the Jail was up to the task of treating him or her. The court found that the Sheriff had not created a policy at all because it was a court order that caused the decedent to be detained at the Jail, which compelled the Sheriff to receive him under Illinois law. The court also disposed of a claim against the Sheriff in his individual capacity, finding that there can be no inference in a Jail the size of McHenry County Jail (which has 650 beds) that the Sheriff is automatically aware of someone like the decedent.


Gonzalez v. McHenry CountyDownload
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