Yates v. City of Chicago, Illinois

Federal 7th Circuit Court
Civil Court
Labor Law
Citation
Case Number: 
Nos. 21-2953 and 22-1109 Cons.
Decision Date: 
January 25, 2023
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in granting defendant-City’s motion for summary judgment in plaintiffs-aviation security officers’ section 1983 action, alleging that defendant’s decision to discontinue recognition of plaintiffs as law enforcement officers (and thus plaintiffs could no longer arrest individuals while employed or carry concealed weapons in retirement) violated their due process rights under 14th Amendment. Plaintiff failed to establish any property interest associated with retention of label as law enforcement officer, and plaintiffs had already received hearing on question of their law enforcement officer status, when Illinois Labor Relation Board ruled against them on said issue. Moreover, plaintiffs could not establish any substantive due process claim, where: (1) no one has “fundamental right” to be law enforcement officer; and (2) any violation of state law associated with withdrawal of recognition of law enforcement officer status is not violation of any right under U.S. Constitution.