O R D E R
Anthony Murdock was arrested and detained by the Chicago Police Department overnight, prompting him to lead a putative class action against the City of Chicago under 42 U.S.C. § 1983. He was later joined by other named plaintiffs, who were arrested in a similar way, seeking to recover damages for alleged constitutional violations stemming from the City's cash-bail policy. That policy prevented anyone arrested by the Chicago Police Department on a weekend, on a court holiday, or on a warrant issued by any court located outside of Chicago, from posting bond at the police station on the day of their arrest. The Plaintiffs argued this policy violated the
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with FED. R. APP. P. 32.1
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Fourteenth Amendment's Equal Protection Clause and the Fourth Amendment's prohibition on unreasonable seizures. The City moved for judgment on the pleadings against each group of named plaintiffs, and the district court granted the motions. For the reasons explained below, we affirm.
I. BACKGROUND
A. Factual Background
When an individual is arrested in Chicago, Illinois, the Cook County court system provides certain rules and policies for those arrests depending on where and how they occurred within its six municipal districts. As relevant here, Amended General Order 2004-02, issued by presiding Judge E. Kenneth Wright, Jr. on the First Municipal District, which governs Chicago, sets forth a procedure for the Chicago Police Department's handling of "Cook County Warrants." See Cook County Cir. Ct. Am. G.O. 2004-02 (Apr. 7, 2004).1The order required that the Chicago Police Department transfer "any individual arrested" on Saturday, Sunday, or a court holiday for a warrant "returnable within the First Municipal District … to Central Bond Court."
Id. Before an individual is transferred, however, the court's order further directs the Chicago Police Department to verify the warrant through the Cook County Sheriff's Office to ensure the warrant is valid and outstanding. See id. For warrants issued by an Illinois state court outside of Cook County, but executed in Chicago, General Administrative Order 2015-06, issued by the Chief Judge of the Circuit Court of Cook County, instructs that these arrestees are to be transferred to "bond court in the appropriate district or division of this court." See Cook County Cir. Ct. G.A.O. 2015-06 (June 17, 2015).2And when the individual arrested "is able to post the bail set on the warrant," the arrestee must be "admitted to bail and scheduled for a court appearance" in the appropriate county. Id.
The City of Chicago, in accord with the circuit court's orders, implemented Special Order S06-12-02 within the Chicago Police Department. Relevant here, Section IV, titled "Processing Persons Arrested on Warrants," provides that "all persons arrested on a warrant outside of the First Municipal District," § IV(B)(3)(a), and "all persons arrested on all warrants on Saturday, Sunday, and Court Holidays,"
§ IV(B)(3)(c), will be transported to Central Bond Court.3This restricted all arrestees
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falling within one of these two categories from posting bond at the Chicago Police Station and being immediately released. In contrast, individuals "arrested on a weekday" on a warrant returnable to the First Municipal District "in Chicago" were able to post bond at the station and obtain immediate release. On Saturday, September 29, 2018, Anthony Murdock was arrested by the Chicago Police Department during a traffic stop for an outstanding warrant out of DuPage County, Illinois. After verifying the warrant at the police station, officers detained Murdock, without bond, pursuant to Section IV(B)(3)(c) of the Special Order. The next day, Murdock was transported to Central Bond Court for a bond hearing where he was later released.
The Chicago Police Department also arrested Andrew Cruz, Johonest Fischer, Maurice Grant, Theresa Kennedy, Chawan Lowe, James McGee, Brian Neals, Myron Nelson, John Perry, Duwayne Richardson, Santiago Bravo, and John Plummer between 2018 and 2022. While some were arrested on weekends and others on non-Chicago warrants, the Chicago Police Department, in compliance with Section IV of the Special Order, detained each person overnight without bond, pending their appearance before Central Bond Court. At no time between their arrest and court appearance were these individuals permitted to post bond for release at the police station, even when the applicable warrant may have designated a bond determination. Once presented to a judge at Central Bond Court, however, these same individuals were able to post bond and be released. The police presented each Plaintiff to Central Bond Court within 48 hours of their arrest.
B. Procedural History
Murdock sued the City under 42 U.S.C. § 1983, individually and on behalf of a putative class, to challenge the constitutionality of Section IV(B)(3)(c) of the Special Order, which applies to all persons arrested on a weekend or court holiday. The City moved three times for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). Before the first motion, Murdock amended his complaint to add ten named plaintiffs and broaden his claims to challenge Section IV(B)(3)(a) in addition to Section IV(B)(3)(c).4The Plaintiffs attached copies of the Special Order as exhibits to
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the amended complaint.5The amended complaint alleged Special Order S06-12-02 violated the Equal Protection Clause of the Fourteenth Amendment by creating arbitrary distinctions between arrestees and impermissibly treating them differently. The Plaintiffs also alleged the Special Order violated their Fourth Amendment right to be free from unreasonable detentions.
The district court granted in part the first Rule 12(c) motion, leaving intact only Plaintiff Kennedy's claims because she was arrested for an outstanding warrant returnable within Chicago and the general administrative order allowed her to post the pre-determined bond amount. After Plaintiff Kennedy successfully moved to add Bravo and Plummer as named plaintiffs, the City filed a second Rule 12(c) motion. The district court again granted in part the City's motion for judgment on the pleadings. The court found that the Plaintiffs' Fourth Amendment claim was foreclosed by our decision in Alcorn v. City of Chicago, 83 F.4th 1063 (7th Cir. 2023), and otherwise failed because the Plaintiffs cited no authority to suggest individuals have a federal right to avoid post-arrest presentation to a judge. The court permitted Plaintiffs Kennedy and Plummer's Fourteenth Amendment Equal Protection claims to proceed. On Plaintiffs' motion for reconsideration and the City's third Rule 12(c) motion, the district court dismissed the Plaintiffs' case on grounds that their injuries were caused by the two circuit court orders rather than the City's policy itself.6 This appeal followed.
II. D ISCUSSION
We review de novo a district court's grant of a motion for judgment on the pleadings, construing the facts in the light most favorable to the non-moving party. Federated Mut. Ins. Co. v. Coyle Mech. Supply Inc., 983 F.3d 307, 313 (7th Cir. 2020).
"Judgment on the pleadings is appropriate if there are no material issues of fact to be resolved and the moving party is entitled to judgment as a matter of law." Muthana v. Mullin, 171 F.4th 967, 973 (7th Cir. 2026) (citation omitted). A court's review of a motion
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for judgment on the pleadings includes the complaint and "documents attached to the complaint, documents that are critical to the complaint and referred to in it, and information that is subject to proper judicial notice." Id. In this context, a court is permitted to "take judicial notice of matters of public record," which includes certain state court orders. Milwaukee Police Ass'n v. Flynn, 863 F.3d 636, 640 (7th Cir. 2017) (citations omitted); United States v. Wood, 925 F.2d 1580, 1582 (7th Cir. 1991); see also Geinosky v. City of Chicago, 675 F.3d 743, 745 n.1 (7th Cir. 2012).
A. Fourteenth Amendment
The Fourteenth Amendment prohibits a state from denying "to any person within its jurisdiction the equal protection of the laws." U.S. CONST. amend. XIV, § 1. This directive commands that "all persons similarly situated should be treated alike."
Vision Church v. Village of Long Grove, 468 F.3d 975, 1000 (7th Cir. 2006). Where, as here, a municipality is sued, the plaintiff must (1) allege "that he suffered a constitutional injury," Thompson v. Boggs, 33 F.3d 847, 859 (7th Cir. 1994); (2) "trace the deprivation to some municipal action (i.e., a policy or custom) … attributable to the municipality itself"; (3) "show municipal fault"; and (4) "show that the municipal action was the moving force behind the federal-rights violation," Lee v. Milwaukee County, 175 F.4th 877, 884 (7th Cir. 2026) (quotation marks omitted); Monell v. Dep't of Soc. Servs. of N.Y.,
436 U.S. 658 (1978). "The first question, therefore, is whether the complaint alleges a direct causal link between a policy or custom of the [municipality] and the alleged constitutional violations." Est. of Sims ex rel. Sims v. County of Bureau, 506 F.3d 509, 515 (7th Cir. 2007).
Here, the answer is no. The Plaintiffs argue the warrant procedures outlined in the Chicago Police Department's Special Order violated the Equal Protection Clause of the Fourteenth Amendment by creating arbitrary distinctions between arrestees and impermissibly treating them differently. Plaintiffs have failed, however, to allege facts that plausibly suggest that the City's Special Order was the moving force behind the alleged federal-rights violation.
To show that the City's action was the "moving force," the Plaintiffs needed to satisfy a "rigorous causation standard," which "guards against backsliding into respondeat superior liability." First Midwest Bank ex rel. LaPorta v. City of Chicago, 988 F.3d 978, 987 (7th Cir. 2021) (citation modified); see Monell, 436 U.S. at 694; see also, e.g., Johnson v. Dossey, 515 F.3d 778, 782 (7th Cir. 2008). Turning to the complaint, the Plaintiffs allege three classifications existed among arrestees: (1) "all persons arrested on a warrant issued outside of the First Municipal District," (2) "all persons arrested on all
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warrants on Saturday, Sunday, and Court Holidays," and (3) all persons arrested on a warrant for which a judge had set an amount of cash bail. While we assume without deciding that these classifications are sufficiently alleged,7the Plaintiffs' Equal Protection claim under the Fourteenth Amendment still fails because the City of Chicago was not the but-for cause of the alleged constitutional violation. These three classifications for arrestees were created by the Circuit Court of Cook County, not the City's Special Order S06-12-02. The First Municipal District's presiding judge in Cook County Circuit Court created the first two classifications. See Cook County Cir. Ct. Am. G.O. 2004-02 (Apr. 7, 2004). And the Chief Judge of the Circuit Court of Cook County created the final classification through the general administrative order. See Cook County Cir. Ct. G.A.O. 2015-06 (June 17, 2015). Because the City's Special Order did not cause the Plaintiffs to be classified for differential treatment, the Plaintiffs have failed to allege sufficient causation. See Sims, 506 F.3d at 515. Without causation, the Plaintiffs' Fourteenth Amendment claims fail, and the district court properly granted the City's motion for judgment on this claim.
B. Fourth Amendment
The Fourth Amendment generally prohibits unreasonable searches and seizures. U.S. CONST. amend. IV. Indeed, "the ultimate touchstone of the Fourth Amendment is reasonableness." Lange v. California, 594 U.S. 295, 301 (2021) (quotation marks omitted). In Alcorn, we addressed whether it violated the Fourth Amendment to delay an arrestee's posting of bond and release until after he appeared before a judge. See 83 F.4th at 1064-65. Relying on the Supreme Court's decision in County of Riverside v. McLaughlin, 500 U.S. 44 (1991), we held that it did not, so long as police present an arrestee to a judge "in a reasonable time not to exceed 48 hours." Alcorn, F.4th at 1065; McLaughlin, 500 U.S. at 56 (holding that the Fourth Amendment generally requires probable cause determinations within 48 hours of arrest).
Despite the Plaintiffs' claims to the contrary, their Fourth Amendment claim fares no better because the district court correctly recognized that Alcorn squarely controls this case. The Chicago Police Department presented each Plaintiff to a judge within 48 hours of arrest. The Plaintiffs' detentions, which occurred before they appeared before a judge, were reasonable under federal law. The Plaintiffs cannot
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prevail on their Fourth Amendment claim. Thus, the district court properly granted the City's motion for judgment on this claim.
Finding no underlying constitutional violation, we do not reach the "policy or custom" inquiry of Monell. See Schor v. City of Chicago, 576 F.3d 775, 779 (7th Cir. 2009) ("Because we have concluded that these plaintiffs have not alleged any plausible constitutional violation committed by [the mayor] or the officers, it follows that there is no wrongful conduct that might become the basis for holding the City liable.").
III. C ONCLUSION
For these reasons, the judgment of the district court is AFFIRMED.
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