Walters v. Ogle County Sheriff

── Walters v. Ogle County Sheriff ── Court: Appellate Court of Illinois Date: May 08, 2026 Category: General NOTICE 2026 IL App (4th) 250792-U This Order was filed under FILED Supreme Court Rule 23 and is May 8, 2026 NO. 4-25-0792 Carla Bender not precedent except in the limited circumstances allowed 4th District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL OF ILLINOIS FOURTH DISTRICT BRADLEY WALTERS, ) Appeal from the Plaintiff-Appellant, ) Circuit Court of v. ) Ogle County THE OGLE COUNTY SHERIFF’S OFFICE, ) No. 24LA24 Defendant-Appellant. ) ) Honorable ) Clayton L. Lindsey, ) Judge Presiding. JUSTICE LANNERD delivered the judgment of the court. Justices DeArmond and Harris concurred in the judgment. ORDER ¶1 Held: The trial court did not err in granting defendant’s motion to dismiss plaintiff’s complaint when the matter was barred by principles of res judicata. ¶2 Plaintiff, Bradley Walters, is a federal detainee housed at the Ogle County jail while awaiting trial for federal criminal charges. In July 2024, plaintiff, appearing pro se, filed a complaint against defendant, the Ogle County Sheriff’s Office (Sheriff’s Office), alleging the Sheriff’s Office violated 20 provisions of the U.S. Marshals Service Federal Performance Based Detention Standards (detention standards) in violation of his rights under the United States Constitution. ¶3 The case was removed to federal court, which dismissed the federal claims with prejudice and relinquished jurisdiction over any state claims. See Walters v. Ogle County Sheriff’s Office, No. 24-cv-50409, (N.D. Ill. Mar. 18, 2025). Plaintiff then filed a first amended complaint in state court alleging the same federal claims. ¶4 The Sheriff’s Office filed a motion to dismiss the complaint pursuant to section 2-615 of the Code of Civil Procedure (735 ILCS 5/2-615 (West 2024)). The trial court granted the motion to dismiss with prejudice. Plaintiff moved to reconsider, seeking leave to file a second amended complaint alleging the same factual allegations but asserting violations of the Illinois Constitution. The court denied the motion. ¶5 On appeal, plaintiff argues the trial court erred in granting the motion to dismiss. We affirm. ¶6 I. BACKGROUND ¶7 In his original complaint, plaintiff alleged the Sheriff’s Office has an agreement with the U.S. Marshals Service to house federal detainees, such as himself, at the Ogle County jail and to follow the detention standards. Plaintiff alleged he was being injured by 20 violations of the detention standards, in violation of his rights under the first, fifth, eighth, and fourteenth amendments to the United States Constitution (U.S. Const., amends. I, V, VIII, XIV). Plaintiff also alleged the violations of the detention standards violated the federal Civil Rights Act (42 U.S.C. § 1983 (2024)). ¶8 The Sheriff’s Office removed the case to federal court, which dismissed the case with prejudice for failure to state a claim. The court referred to an “amended complaint” in