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UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF ILLINOISEASTERN DIVISION
LINDA L. SHELTON)Plaintiff)) Case Number 09 C 6413Vs.))Hon. Judge DowCOOK COUNTY SHERIFF )COURTROOM SERVICES SERGEANT)Hon. Maj. Judge KeysRACHEL WRIGHT, in her individual)and official capacity, COOK COUNTY)SHERIFF COURTROOM SERVICES)ASSISTANT CHIEF ALLEN, in his)individual and official capacity, COUNTY)OF COOK, COOK COUNTY SHERIFF)Filed October 13, 2009COURTROOM SERVICES DEPUTIES)JANE AND JOHN DOES, in their )individual and official capacities)
COMPLAINTJURISDICTION
1.Jurisdiction of the Court is invoked pursuant to the Civil Rights Act, 42 U.S.C §1981 et seq.: the Judicial Code, 28 U.S.C. §§ 1331, 1343(a) and 1391, the Constitution of the United States; and pendent and supplementary jurisdiction pursuant to 28 U.S.C. §1367.
PARTIES
2.Defendants Wright, Allen, and Jane and John Does (names presently unknown),during the cause of this action, were employed by Cook County in the Cook CountySheriff’s Division of Courtroom services, and were working at 555 W. Harrison inChicago on October 10, 2007.1
 
3.Defendant County of Cook is a municipal corporation, duly incorporated under the laws of the State of Illinois, and is the employer of all of the defendants and operator of the courthouse at 555 W. Harrison, Chicago, Illinois.4.Plaintiff during the cause of this action was a resident of Cook County, Illinois.
FACTS OF THE CASE
5.On October 10, 2007, Plaintiff entered the courthouse at 555 W. Harrison,Chicago, Illinois, to pick up a copy of a document from the Circuit Court Clerk of Cook County.6.Plaintiff had in her possession a medical bag containing her portable nebulizer, a battery pack for it, an electric cord to use if the battery pack failed, and appropriatemedication to use with it for the purpose of treating her poorly controlled and severeintermittent asthma.7.Plaintiff also had in her possession an order form Circuit Court of Cook CountyJudge Kathleen Pantle granting request to bring the medications and equipment toadminister it into the courthouse.8.Plaintiff entered through security, giving her briefcase containing her bag to thedeputy to put through the security scanner, along with her cane, and she walked throughthe magnetometer.9.The magnetometer did NOT alarm or beep and this is documented on the securitysurveillance video tapes of this incident, as alarms trigger flashing lights and there wereno flashing lights.2
 
10.The security officer at the scanner asked about the medical bag, took out andexamined the cord, and returned it to Plaintiff, while making no physical attempt to prevent Plaintiff from walking towards the Clerk’s office.11.Defendant Allen, in plain clothes observed the security scanner and told thesecurity officer that “cords were not allowed in the building”.12.Thinking Defendant Allen was some kind of nut, interfering with the securityofficer’s duties, Plaintiff loudly stated that she always brings her medical bag into the building and had done so dozens of times, that the equipment was necessary, and that shehad permission to bring it into the building.13.Plaintiff then walked with her cane about 50-100 yards to the entrance of theClerk’s office.14.At the entrance while standing in the hallway and NOT obstructing anyone’sentrance to the office, Plaintiff was assaulted by Defendant Allen and several deputies,who falsely claimed that Plaintiff had bypassed security and refused to go throughsecurity.15.Plaintiff stated firmly to cease the assault, to stand aside and that she had gonethrough security.16.Defendant Allen and these other male deputies physically impeded Plaintiff’saccess to the Clerk’s office.17.Defendant Wright arrived and talked with Plaintiff. She kept saying Plaintiff hadrefused to go through security and Plaintiff kept saying she was being assaulted andalready went through security. Defendant Wright insisted Plaintiff had to leave the building because she did not participate in security procedures.3
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