Janusz v. City of Chicago

Dist. Ct. did not err in granting defendants-police officials’ motion for summary judgment in section 1983 action alleging that defendants unlawfully arrested plaintiff, after finding that single-recovery rule applied so as to preclude plaintiff from obtaining any damages in instant lawsuit. Record showed that plaintiff had settled prior related state-court action alleging breach of employment contract and emotional distress damages for conduct that occurred following instant arrest, that parties to state court action entered into settlement, which contained stipulation that defendant in that case had paid plaintiff all monies (i.e., $3 million) due and owing to him as result of $3,177,500 judgment previously entered against said defendant, and that trial court vacated and dismissed state-court action pursuant to section 12-183(h) of Code of Civil Procedure due to said stipulation. As such, dismissal of instant action was required under Saichek, 787 N.E. 2d 827, since single-recovery rule precluded plaintiff from obtaining similar damages in instant case due to plaintiff‘s stipulation in prior case, and plaintiff's stipulated in instant matter that there were no other damages at issue in instant case. Also, doctrine of judicial estoppel precluded plaintiff from maintaining in instant action that state-court judgment was not fully satisfied.