Crosby v. City of Chicago

Dist. Ct. did not err in entering judgment in favor of defendant in section 1983 action against defendants-City and others alleging malicious prosecution and unlawful detention arising out of incident in which police officer had allegedly pushed plaintiff out of window prior to his arrest on charges under Ill. armed career criminal statute. Instant action was precluded by release that plaintiff had given in prior settlement of 1983 action alleging excessive force against police officer involved in instant arrest, where language in release indicated that release covered all claims against defendant City, “including but not limited to all claims under…state or federal law, arising either directly or indirectly” out of incident which was basis of instant litigation. Ct. rejected plaintiff’s claim that scope of release covered only prior excessive force action, where Ct. found that release was designed to resolve all claims related to plaintiff’s arrest and not only ones that plaintiff asserted in first lawsuit. Moreover, claims in instant lawsuit were reasonably foreseeable to parties at time release was generated.