Conyers v. City of Chicago

Dist. Ct. did not err in granting defendant-City’s motion for summary judgment in plaintiffs-jail detainees’ section 1983 claim that challenged defendant’s policy that required arrested individuals housed in Cook County Jail to retrieve within 30 days their property that had been seized upon their arrest (because said property was not allowed in jail) or else face prospect of having said property be deemed abandoned for purposes of allowing defendant to sell or destroy said property. Ct. rejected plaintiffs’ claim that instant seizure and disposal of their property violated Takings Clause, where record showed that: (1) defendants provided written notice to plaintiffs of how to retrieve their property; (2) defendant could treat as abandoned any property that was unclaimed after 30 days; and (3) because abandoned property belongs to no one, defendant could dispose of said property as it saw fit. Ct. further found that 30-day notice was adequate for purposes of due process clause, where: (1) 30-day period was reasonable based on defendant’s ability to store said property; (2) content on defendant’s webpage provided sufficient information to allow prisoner or his or her representative to retrieve prisoner’s property; (3) record showed that website was active during relevant period; and (4) record showed, as practical matter, that prisoners had access either personally or through correctional worker to defendant’s website.