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Wednesday, September 27, 2023

Court Rejects Lawsuit Challenging City Officials' Social Media Posts

A resident (plaintiff) filed a lawsuit against a village, certain village officials, and a resident seeking damages for a variety of claims, including invasion of privacy, false light, disclosure of private facts, intrusion upon seclusion, and intentional infliction of emotional distress. The complaint claimed that the defendants posted various false statements about her on social media. The plaintiff also claimed that the defendants had obtained police reports about her and posted private medical information about her on social media. The plaintiff also alleged that the actions by defendant were in retaliation for her vocal comments criticizing one of the defendants fitness to serve as an elected official. One of the defendants settled with the plaintiff and the trial court dismissed the remainder of her case and rejected plaintiff's motion for sanctions, and she appealed to the Illinois Appellate Court. Williams v. Stuckly.

First, the Appellate Court rejected plaintiff's privacy and intrusion upon seclusion claims, finding that her allegations related to the publication of records that had been obtained through lawful means (FOIA) and that there was no evidence to support an expectation of privacy in the police reports disclosed through FOIA.

Second, the Appellate Court determined that there were insufficient factual allegations to support her false light claim and those that were included in the complaint were too vague and unclear.

Third, the Appellate Court upheld the dismissal of her conspiracy claim since that claim requires an underlying cause of action but all of her underlying claims had been dismissed. 

Finally, the Appellate Court determined that the plaintiff's motion for sanctions against one of the defendants was not well founded where plaintiff was seeking sanctions against a defendant despite the dismissal of the plaintiff's entire case. 

In sum, the Appellate Court upheld the trial court's dismissal with prejudice, finding that the plaintiff had been given three opportunities to plead an adequate complaint and had failed to do so.


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