Worthington v. Wilson

Facts

Worthington (P) was arrested by a police officer. P had an injured left hand, and he advised the arresting officer of his injury. It is alleged that the arresting officer responded by grabbing P's injured hand and twisting it, prompting P to push the officer away and tell him to 'take it easy.' A second police officer arrived, and P was wrestled to the ground and handcuffed. The officers then hoisted P from the ground by the handcuffs, which caused him to suffer broken bones in his left hand. Exactly two years later, P filed a complaint against the Village of Peoria Heights and 'three unknown named police officers,' stating the above facts and alleging that he was deprived of his constitutional rights in violation of 42 U.S.C. § 1983. The Village removed the action to federal court and sought dismissal under Fed.R.Civ.P. 12(b)(6) for the reason that respondeat superior was not a valid basis for imposing liability against it under § 1983. P voluntarily dismissed his claims against the Village and obtained leave to file an amended complaint. The Village thereafter moved for sanctions against Worthington and his counsel under Fed.R.Civ.P. 11. Village argued that P's attempt to state a § 1983 claim against it on the basis of respondeat superior was contrary to case law and therefore in violation of Rule 11. P filed an amended complaint and substituted as the defendants Wilson and Wall (Ds) for the 'unknown named police officers' who arrested him on February 25, 1989. Ds moved to dismiss the amended complaint primarily on grounds that Illinois' two-year statute of limitations expired and the amendment did not relate back to the filing of the original complaint under Rule 15(c). The district judge granted D's motion to dismiss the amended complaint under revised Rule 15(c) and denied the Village's motion for sanctions. P appeals this dismissal. The Village cross-appeals the denial of sanctions.

Issues

Rule of Law

Holding and Decision

Legal Analysis

© 2007-2024 ABN Study Partner.