Ramos v. Piech

Dist. Ct. did not err in granting defendants-correctional officers’ motion for summary judgment in plaintiff-prisoner’s section 1983 action, alleging that defendants unlawfully arrested plaintiff in 2016. Basis of defendants’ motion was their contention that said lawsuit was barred by language contained in 2017 releases in settlements of plaintiff’s prior 2014 section 1983 actions that concerned plaintiff’s claims that different Cook County jail correctional officers had failed to protect him and used excessive force. Dist. Ct. could properly find that language in 2017 settlements of first lawsuits that released Cook County and its employees from “any and all claims,” covered instant lawsuit, even though 2016 arrest at issue in instant lawsuit occurred after events at issue in first lawsuits, but prior to execution of 2017 settlements of first lawsuits. Ct. rejected plaintiff’s contention that his claims against instant defendants were not contemplated at time he signed 2017 settlement agreements, after noting that settlement agreements contained “general release,” which covered all claims, which plaintiff as signing party had actual knowledge or claims that he could have discovered upon reasonable inquiry.