Campbell v. Forest Preserve District of Cook County, Ill.

Dist. Ct. did not err in dismissing plaintiff’s section 1981 action alleging that defendant-Forest Preserve District terminated him on account of his race. Under Jett, section 1981 does not create private cause of action against state actors, and while defendant could bring similar action against instant state actor under section 1983, instant lawsuit was filed beyond applicable two-year period for section 1983 claims. Ct. rejected defendant’s claim that result in Jett was superseded by Civil Rights Act of 1991.