Respondents Brief — Courthouse News Service, Petitioner v. Dorothy Brown, Clerk, Circuit Court of Illinois, Cook County

No. 18-1203

In the

Supreme Court of the United States

COURTHOUSE NEWS SERVICE,

Petitioner,

v.

DOROTHY BROWN, CLERK OF THE CIRCUIT COURT

OF COOK COUNTY, IN HER OFFICIAL CAPACITY,

Respondent.

On Petition for a Writ of Certiorari to the United

States Court of A ppeals for the Seventh Circuit

BRIEF IN OPPOSITION

Cathy McNeil Stein

Kimberly M. Foxx

Assistant State’s Attorney

Cook County State’s

Chief, Civil Actions Bureau

Attorney

500 Richard J. Daley Center

Paul A. Castiglione*

Chicago, Illinois 60602

Prathima Yeddanapudi

(312) 603-2350

Assistant State’s Attorneys

paul.castiglione

Counsel for Respondent

@cookcountyil.gov

Of Counsel

* Counsel of Record

288306

A

(800) 274-3321 • (800) 359-6859

i

QUESTION PRESENTED

Whether the abstention doctrines of Younger,

O’Shea and Rizzo preclude the exercise of subject matter

jurisdiction over a federal lawsuit where the plaintiff asks

the district court to direct the manner in which state

courts process newly e-filed civil complaints and makes

them available to the public and the press.

ii

TABLE OF CONTENTS

Page

QUESTION PRESENTED . . . . . . . . . . . . . . . . . . . . . . . . i

TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . ii

TABLE OF CITED AUTHORITIES . . . . . . . . . . . . . . . iv

STATEMENT OF THE CASE . . . . . . . . . . . . . . . . . . . . 1

I.

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

A. The Relevant Facts and Applicable

State Court Rules and Orders . . . . . . . . . . . 3

II. Proceedings Below . . . . . . . . . . . . . . . . . . . . . . . . . 7

A. CNS ’s Mot ion for P r el i m i n a r y

Injunction . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

B. The Circuit Clerk’s Motion to Stay

The Preliminary Injunction . . . . . . . . . . . . . 9

C. The Court of Appeals’ Decision . . . . . . . . . 13

REASONS FOR DENYING THE PETITION . . . . . 16

I.

It Is Unclear Whether Planet Is The

Law of The Ninth Circuit Regarding The

Proper Application of O’Shea and Rizzo . . . . . . 18

iii

Table of Contents

Page

II. The Second Circuit Recently Followed

Brown . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

III. Planet Is an Outlier and Does Not

Create a Sufficient Enough Split Among

The Circuits to Warrant The Granting

of CNS’s Writ of Certiorari . . . . . . . . . . . . . . . . . 23

IV. Brown Was Correctly Decided . . . . . . . . . . . . . . 26

CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

iv

TABLE OF CITED AUTHORITIES

Page

CASES

Burford v. Sun Oil Co.,

319 U.S. 315 (1943) . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Carlton v. United States,

135 S. Ct. 2399 (2015) . . . . . . . . . . . . . . . . . . . . . . . . . 20

Colorado River Water Conservation District v.

United States,

424 U.S. 800 (1976) . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Courthouse News Service v. Brown,

908 F.3d 1063 (7th Cir. 2018) . . . . . . . . . . . . . . . passim

Courthouse News Service v. Planet,

750 F.3d 776 (9th Cir. 2014) . . . . . . . . . . . . . . . . passim

Disability Rights New York v. New York,

916 F.3d 129 (2d Cir. 2019) . . . . . . . . . . . . . . . . . passim

Drury v. County of McLean,

433 N.E.2d 666 (Ill. 1982) . . . . . . . . . . . . . . . . . . . . . . 26

E.T. v. Cantil-Sakauye,

682 F.3d 1121 (9th Cir. 2012) . . . . . . . . . . . . . . . passim

Hartford Courant Co. v. Pellegrino,

380 F.3d 83 (2d Cir. 2004) . . . . . . . . . . . . . . . . 16, 17, 21

v

Cited Authorities

Page

Kaufman v. Kaye,

466 F.3d 83 (2d Cir. 2006) . . . . . . . . . . . . . . . . . . . 23, 29

Miles v. Wesley,

801 F.3d 1060 (9th Cir. 2015) . . . . . . . . . . . . . . . passim

New Orleans Public Service, Inc. v.

Council of New Orleans,

491 U.S. 350 (1989) . . . . . . . . . . . . . . . . . . . . . 13, 25, 26

Oglala Sioux Tribe v. Fleming,

904 F.3d 603 (8th Cir. 2018) . . . . . . . . . . . . . . . . . . . . 23

O’Shea v. Littleton,

414 U.S. 488 (1974) . . . . . . . . . . . . . . . . . . . . . . . passim

Parker v. Turner,

626 F.2d 1 (6th Cir. 1980) . . . . . . . . . . . . . . . . . . . 23, 29

Railroad Commission of Texas v. Pullman Co.,

312 U.S. 496 (1941) . . . . . . . . . . . . . . . . . . . 14-15, 17, 18

Rizzo v. Goode,

423 U.S. 362 (1976) . . . . . . . . . . . . . . . . . . . . . . . passim

SKS & Associates, Inc. v. Dart,

619 U.S. 674 (7th Cir. 2010) . . . . . . . . . . . . . . . 2, 13, 14

Sprint Communications, Inc. v. Jacobs,

571 U.S. 69 (2013) . . . . . . . . . . . . . . . . . . . . . . . . . 25, 26

vi

Cited Authorities

Page

In re Swan,

415 N.E.2d 1354 (Ill. App. Ct. 1981) . . . . . . . . . . . . . 26

Younger v. Harris,

401 U.S. 37 (1971) . . . . . . . . . . . . . . . . . . . . . . . . passim

STATUTES, RULES, AND ORDERS

410 ILCS 325/1 (2019) . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

410 ILCS 535/15.1 (2019) . . . . . . . . . . . . . . . . . . . . . . . . . 28

705 ILCS 105/13 (2019) . . . . . . . . . . . . . . . . . . . . . . . . . . 26

750 ILCS 70/1 (2019) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

General Administrative Order 2014-02 dated June 13,

2016 from the Circuit Court of Cook County . 3, 8, 28

Electronic Filing Standards and Principles

from the Illinois Supreme Court amended

September 16, 2014 . . . . . . . . . . . . . . . . . . . . . . 3, 5, 8, 9

vii

Cited Authorities

Page

CONSTITUTIONAL PROVISIONS

U.S. Const. amend. I . . . . . . . . . . . . . . . . . . . . . . 14, 18, 30

U.S. Const. amend. VI . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

U.S. Const. amend. VIII . . . . . . . . . . . . . . . . . . . . . . . . . 30

U.S. Const. amend. XIII . . . . . . . . . . . . . . . . . . . . . . . . . 30

U.S. Const. amend. XIV . . . . . . . . . . . . . . . . . . . . . . . . . 30

1

STATEMENT OF THE CASE

Petitioner Courthouse News Service (“CNS” or

“Petitioner”) filed a complaint challenging the manner in

which respondent Dorothy Brown, the Clerk of the Circuit

Court of Cook County (the “Circuit Clerk” or “Respondent”),

makes electronically submitted complaints available to

CNS and the press. (R. 1.)1 CNS alleged that the First

Amendment mandates “[c]ontemporaneous access to new

civil complaints” and that “the [Circuit] Clerk’s policy

and practice of withholding new e-filed complaints from

press review until after the performance of administrative

processing, including post-filing ‘acceptance’ of the

complaint” violates the First Amendment. (Id. ¶¶ 1, 4, 7.)

While CNS challenged the Circuit Clerk’s practice

of accepting or rejecting newly filed complaints before

1. In this Brief in Opposition, Respondent will cite the

following documents from the record: CNS’s complaint (R. 1),

its motion for preliminary injunction (R. 6), its memorandum

in support of its motion for preliminary injunction (R. 7), the

Circuit Clerk’s memorandum in opposition to CNS’s motion for

preliminary injunction (R. 19), the Circuit Clerk’s motion to clarify

the district court’s order of January 8, 2018 order granting CNS’s

motion for preliminary injunction (R. 24), the district court’s order

of January 27, 2018 (R. 27), the Circuit Clerk’s notice of appeal

(R. 30), the motion to stay the preliminary injunction order that

the Circuit Clerk filed in the district court (R. 35.) and the district

court’s denial of the motion to stay (R. 44). Respondent will also cite

the motion to stay the district court’s preliminary injunction order

(7th Cir. R. 3) and the stay order from the Seventh Circuit. (7th

Cir. R.5.) As these documents are not attached to the appendix to

CNS’s petition for a writ of certiorari (the “Petition”), Respondent

will cite to the above docket entries in the electronic district court

and circuit court records.

2

making them available to CNS or the media, it did not

challenge the applicable Illinois Supreme Court rule or

the order from the Hon. Timothy Evans, the Chief Judge

of the Circuit Court of Cook County (the “Chief Judge”),

both of which directed her to follow this practice. (Id.

¶ 7.) Instead, CNS filed a federal lawsuit asking that the

district court enter an order directing the Circuit Clerk

to provide CNS with immediate and contemporaneous

access to newly e-filed civil complaints. (Id. at 18, ¶ 1.)

On November 8, 2017, CNS moved for a motion for

preliminary injunction against the Circuit Clerk directing

her to provide it with immediate access to complaints

submitted electronically to the Circuit Clerk’s office but

not yet accepted for filing. (R. 6.)

The district court entered a preliminary injunction

directing the Circuit Clerk to provide immediate and

contemporaneous access to such e-filed complaint. (Pet.

App. 25-43.) The Circuit Clerk appealed. (R. 30.) The

Seventh Circuit stayed the preliminary injunction during

briefing. Courthouse News Services v. Brown, 908 F.3d

1063 (7th Cir. 2018). (7th Cir. R. 5). After briefing and

oral argument, the Seventh Circuit concluded that “[t]his

temporal access dispute with a state court clerk should be

heard first in the state courts.” Brown, 908 F.3d at 1075

(Pet. App. 23). Relying upon the abstention principles from

Younger v. Harris, 401 U.S. 37 (1971), O’Shea v. Littleton,

414 U.S. 488 (1974), Rizzo v. Goode, 423 U.S. 362 (1976),

and SKS & Associates, Inc. v. Dart, 619 F.3d 674 (7th Cir.

2010) (“SKS”), the Seventh Circuit reversed the district

court’s decision and remanded the case with instructions

to dismiss the action without prejudice. Id. at 1071, 1075.

3

I.

Background.

The parties below litigated CNS’s motion for

preliminary injunction based upon the attachments that

CNS made to its motion for preliminary injunction, as

well as the undisputed rules and orders from the Circuit

Court of Cook County, Illinois that governed the Circuit

Clerk’s responsibilities with respect to the processing of

e-filed complaints.

A.

The Relevant Facts and Applicable State Court

Rules and Orders.

In the district court, the parties submitted declarations

with respect to CNS’s motion for preliminary injunction.

CNS attached two declarations to its motion for

preliminary injunction, one from William Girdner and one

from Adam Angione. (R. 7-2.; 7-4.) The Girdner declaration

touches upon the operation of the Circuit Clerk’s office

but does not discuss the Circuit Clerk’s practices and

procedures for complying with the requirements of

General Administrative Order 2014-02 dated June 13, 2016

from the Circuit Court of Cook County (“Order 2014-02”)

(R. 19-2) and Electronic Filing Standards and Principles

from the Illinois Supreme Court amended September 16,

2014 (the “Standards”) (R. 19-3). (See generally R. 7-2.)

The Angione declaration states that CNS has analyzed

2,414 complaints that were submitted electronically

from June 1, 2017 to September 30, 2017 and that 85.5%

of those complaints were available either the day they

were submitted or the next day. (R.7-5, at 33.) Of the

remaining 14.5%, many of the submitted complaints were

filed the next business day. Id. CNS, for example, lists

4

154 complaints electronically filed between June 2, 2017

and October 2, 2017 as posted three days later. (Id. at 33130.) Of the 154 complaints, 131 complaints were filed on a

Friday and posted one business day later on the following

Monday or in the case of Labor Day, the following Tuesday.

(Id.; R. 19 at 3 n.4.)

CMS admits that 2063 electronically submitted

complaints were posted on the same day or the next

day within the June 2, 2017 to September 30, 2017 time

period. (R. 7-5 at 33.) Of the 2,414 complaints submitted

electronically within the June 2, 2017 to September 30, 2017

time period, 2194 (or 90.9%) were filed within one business

day after submission. (Id. at 33-130.) 2287 (or 94.7%) were

filed within two business days after submission. (Id.) 2337

(or 96.8%) were filed within three business days after

submission. Id. 2 It is undisputed that the vast majority

of electronically submitted complaints are made public,

and viewable, within twenty-four business hours of filing.

(R. 19-1, Decl. of Kelly Smeltzer, General Counsel of the

Circuit Clerk’s office, ¶ 7.)

The Circuit Clerk’s office provides for electronic

filing of pleadings in the Chancery, Child Support, Civil,

Domestic Relations, Law and Probate Divisions of the

2. Ninety-three complaints were filed within two business

days after electronic submission. (Id.) Fifty complaints were

filed within three business days after electronic submission. (Id.)

Twelve complaints were filed within four business days after

electronic submission. (Id.) Seven complaints were filed within

five business days after electronic submission. (Id.) Thirty-six

complaints were filed within six business days after electronic

submission. (Id.) And eighteen complaints were filed within seven

business days after electronic submission. (Id.)

5

Circuit Court of Cook County. (Id. ¶ 3.) As of 2016, more

than 300,000 e-filings had been processed, more than

50,000 e-filed motions had been spindled, and e-filing was

available twenty-four hours a day and seven days a week

to more than 30,000 registered users. (Id. ¶ 5.) During

its business hours from 8:30 a.m. through 4:30 p.m., the

Circuit Clerk’s office reviews electronically submitted

complaints as promptly as possible to ensure compliance

with Order 2014-02 and the Standards. (Id. ¶ 9.)

The Circuit Clerk’s office ensures that a majority of

new civil complaints are viewable within approximately

twenty-four business hours of submission. (Id. ¶ 11.) The

exception is when a case is received after 4:30 pm on a

Friday, and over the weekend, especially a long holiday

weekend. (Id.) For instance, if a case is received on Friday

after 4:30 pm, it is accessible on Monday, or the next court

business day. (Id.)

In the Standards, the Illinois Supreme Court issued

several orders to circuit clerks in Illinois, inter alia:

No. 4

Electronic Access to Court Records

. . . Electronic access and dissemination of

court records shall be in accordance with the

Electronic Access Policy for Circuit Court

Records of the Illinois Courts.

***

(R. 19-3, § 4.) This rule, therefore, incorporates the

Electronic Access Policy for Circuit Court Records of the

Illinois Courts (the “Electronic Access Policy”). (R. 24-1.)

6

The Electronic Access Policy for Circuit Court Records

of the Illinois Courts states that it is “an official policy of

the Administrative Office of the Illinois Courts.” (Id. at i.)

Section 1.00 (c) of the Electronic Access Policy states

that:

Each circuit court that wishes to provide

electronic access to the court records maintained

by any clerk of court within its jurisdiction

must adopt a local rule or administrative order

consistent with this policy.

(R. 24-1, § 1.00(c).)

Section 2.00(c) of the Electronic Access Policy defines

the word “public” to include media organizations. (R. 241, § 2.00(c).)

Section 4.30(b) of the Electronic Access Policy states,

inter alia:

The following information is excluded from

public access in electronic form, unless access

is provided at the office of the clerk of the court

***

Any documents filed or imaged, i.e. complaint,

pleading order.

(R. 24-1, § 4.30(b).) Under the Standards and Order 201402, complaints that are electronically submitted to the

Circuit Clerk are not actually “filed” until the Circuit

7

Clerk’s office determines that they do not improperly

include excluded documents. (R. 19-1, ¶¶ 11, 12.) In making

this determination, the Circuit Clerk performs an “accept/

reject” function. 3 (Id.)

Order 2014-02 sets forth thirteen categories of

excluded documents, including documents containing

confidential information and documents containing

personal identity information. (R. 19-2, ¶ 2(c).) The Circuit

Clerk needs time to determine whether newly submitted

complaints have attachments that are prohibited by Order

2014-02.

II. Proceedings Below.

A.

CNS’s Motion for Preliminary Injunction.

On November 2, 2017, CNS filed its complaint for

declaratory and injunctive relief against Brown, (R. 1),

and on November 8, 2017, CNS moved for a preliminary

injunction. (R. 6.)

The district court granted CNS’s motion for preliminary

injunction and directed the Circuit Clerk to provide

Plaintiff and the public with “timely, contemporaneous

access to the complaints upon filing.” (Pet. App. 26.)

3. “The district court did not interpret these orders as

mandating an ‘accept/reject’ process before release.” Brown, 908

F.3d at 1066, n. 2. The Seventh Circuit, however, reached a different

conclusion and stated that the “orders do require an ‘accept/reject’

process before release.” Id. The Seventh Circuit further stated

that “as we explain below regarding abstention, the Illinois state

courts are best situated to interpret their own orders and to decide

how important the ‘accept/reject’ process is to them.” Id.

8

On January 10, 2018, the Circuit Clerk filed a motion

to clarify the preliminary injunction order, based upon

her concern that the preliminary injunction could not be

reconciled with the commands in Sections 1.00(c), 2.00(c)

and 4.30(b) of the Electronic Access Policy and Point

Number 4 of the Standards. (R. 24, ¶ 12.)

Specifically, the Circuit Clerk expressed concern

that the directive to provide the public with “timely,

contemporaneous access to the complaints upon filing”

cannot be reconciled with certain language from Order

2014-02. (R. 24, ¶ 13.) Section 13(b) of Order 2014-02

(“Section 13(b)”) states that:

Consistent with the Illinois Supreme Court’s

“Electronic Access Policy for Circuit Court

Records of the Illinois Courts,” the Clerk may

permit public access to the electronic forms of

images of electronically filed documents only

through public access computer terminals

located in the Clerk’s office locations. These

public access terminals do not permit the

data, documents, images, or information to be

downloaded or exported in electronic form.

(R. 19-2, ¶ 13(b).) The district court denied the motion

to clarify as moot, on the grounds that the preliminary

injunction order did not conflict with the requirement in

Section 13(b) that electronic images showing court filings

can only displayed at public access terminals in the Circuit

Clerk’s office within business hours. (R. 27.)

On January 31, 2018, the Circuit Clerk filed her notice

of appeal. (R. 30.)

9

B. The Circuit Clerk’s Motion to Stay The

Preliminary Injunction.

On February 2, 2018, the Circuit Clerk filed a motion

to stay the preliminary injunction order in the district

court. (R. 35.) The motion sought a stay until the Seventh

Circuit decided the appeal in the instant case. (Id. ¶ 22.) In

this motion, the Circuit Clerk addressed several practical

problems that implementing the preliminary injunction

order would pose. (Id. ¶¶ 9, 11-14, 18-20.)

The Circuit Clerk noted that the computer system

in the Circuit Clerk’s office does not currently have a

read function that allows users—be they the press or

the general public—to see filed images on the internet.

(Id., ¶ 9.) In order for CNS or other users to be able to

download complaints filed electronically, the Circuit

Clerk’s computer system will need a significant upgrade.

(Id.)

The Circuit Clerk stated that her primary problem

was that the contemporaneous requirement in the

preliminary injunction cannot be reconciled with the rules

of the Electronics Access Policy and the Standards. (Id.

¶ 11.) Both the rules of the Illinois Supreme Court and

the order of the Chief Judge of the Circuit Court of Cook

County “require the Circuit Clerk to complete the ‘accept/

reject function’ before providing a newly filed complaint

to the public, including the media.” (Id.)

The Circuit Clerk also identified another problem:

the Illinois Supreme Court issued an order in the matter

styled, In re: Mandatory Electronic Filing In Civil Cases,

M.R. 18368, dated December 22, 2017, that limits and

10

controls the resources that the Circuit Clerk may apply

to the creation of an e-filing system. (Id., ¶ 14.) Paragraph

4 of this order states:

The Circuit Clerk’s office shall commit all

necessary resources to meet the extended

timeline [of permissive e-filing for six months],

including working with [computer provider]

Tyler on thorough testing of the essential

functionality that the Circuit Clerk has

identified is necessary to maintain the integrity

of its business processes.

(R. 35-3, ¶ 4.) In other words, the Illinois Supreme

Court ordered the Circuit Clerk to devote all necessary

resources to the creation of a mandatory e-filing system,

which would certainly be affected by the re-direction

of resources to a new computer related issue regarding

contemporaneous access to newly submitted complaints

prior to the office’s completion of its mandated accept/

reject function. It is currently the accept/reject function

that initiates the computer system to allow access to an

electronically submitted document. (R. 19-1, ¶ 9) Under

the current design of the computer system in the Circuit

Clerk’s office, complaints that must be sealed cannot be

sealed until the “accept/reject function” is completed. (R.

35-18.)

The Circuit Clerk noted that on January 26, 2018, in

the matter styled In re: Mandatory Electronic Filing In

Civil Cases, M.R. 18368, the Circuit Clerk filed a petition

with the Illinois Supreme Court. (R. 35-1.) This petition

contains the following prayer for relief:

11

WHEREFORE, in an effort to comply with

Judge Kennelly’s January 8, 2018, order the

undersigned respectfully requests that this

Court grant permission to the office of the

Clerk of the Circuit Court to allow access, to

the press and the public, to images submitted

electronically to the Clerk’s office, prior to the

completion of the accept/reject function, which

have not been processed and officially accepted

as a part of the basic record, during business

hours on the Clerk’s Office’s terminals, which

also means that the press and public will have

access to documents that litigants file under

seal. In addition, we request permission to

engage our stand-alone e-Filing vendor as well

as the Clerk’s Office’s programmers to add a

new e-Filing transaction by February 7, 2018.

(Id. at 2.) On February 14, 2018, the Illinois Supreme

Court entered an order denying this petition. Order, In

re: Mandatory Electronic Filing In Civil Cases, M.R.

18368, (Ill. 2018).4 The order stated:

This cause coming to be heard on the petition

of the Cook County Circuit Court Clerk for

relief from certain orders of this court related

to e-Filing on the grounds that such relief is

necessary to permit her office to comply with

the order entered by U.S. District Court Judge

Matthew F. Kennelly in Courthouse News

Services v. Clerk of the Circuit Court of Cook

4. Available at http://www.illinoiscourts.gov/SupremeCourt/

Announce/2018/021418.pdf.

12

County, 2018 U.S. Dist. Lexis 2816 (N.D. Ill.

Jan. 8, 2018), and the Court being fully advised

in the premises;

IT IS ORDERED that the petition is denied.

Id.

On January 29, 2018, the Circuit Clerk sent a letter

to the Chief Judge. (R. 35-2.) In this letter, the Circuit

Clerk stated, in part:

Since documents that are submitted to the

Clerk’s Office prior to the completion of the

accept/reject function are not a part of the

official court record and they do not become a

part of the official court record until they are

officially accepted or rejected by the Clerk’s

Office, we will need GAO 2014-02 to be amended

to allow the Clerk’s Office to provide access to

the press and to the public to unofficial versions

of electronically submitted documents.

(Id.)

The district court denied the Circuit Clerk’s motion

to stay. (R. 44.) On February 13, 2018, the Circuit Clerk

then filed a motion to stay the preliminary injunction order

in the Seventh Circuit. (7th Cir. R. 3.) On February 14,

2018, the Seventh Circuit granted the motion and stayed

the preliminary injunction order “pending a decision by

this court on the merits of the appeal.” (7th Cir. R. 5.).

13

C.

The Court of Appeals’ Decision.

The Seventh Circuit reversed the preliminary

injunction and remanded the case to the district court

with instructions to dismiss. Brown, 908 F.3d at 1075. In

reaching this conclusion, the Seventh Circuit noted that

the fact pattern of the instant case “is quite similar to SKS

& Associates, Inc. v. Dart, 619 F.3d 674 (7th Cir. 2010),

where we applied the principles of Younger and declined

to exercise jurisdiction over a Section 1983 action against

the Chief Judge and the Sheriff of Cook County.” Id. at

1073 (citing SKS, 619 F.3d at 676).

In SKS, the residential property manager plaintiff

sought a federal injunction against the Sheriff to speed up

the eviction processes in state court. The Seventh Circuit

found that abstention precluded the exercise of federal

jurisdiction over the property manager’s claim and noted

that federal courts should have

a proper respect for state functions, a recognition

of the fact that the entire country is made up

of a Union of separate state governments, and

a continuance of the belief that the National

Government will fare best if the States and

their institutions are left free to perform their

separate functions in their separate ways.

SKS, 619 F.3d at 678 (citing New Orleans Public Service,

Inc. v. Council of New Orleans, 491 U.S. 350, 364 (1989),

citing in turn, Younger 401 U.S. at 44). The Seventh

Circuit recognized that “[u]nderlying Younger abstention

is a deeper principle of comity: the assumption that state

courts are co-equal to the federal courts and are fully

14

capable of respecting and protecting CNS’s substantial

First Amendment rights.” Brown, 908 F.3d at 1074.

With respect to CNS’s First Amendment claim, the

Seventh Circuit found that

[t]his principle of comity takes on special force

when federal courts are asked to decide how

state courts should conduct their business. The

Illinois courts are best positioned to interpret

their own orders, which are at the center of

this case, and to craft an informed and proper

balance between the state courts’ legitimate

institutional needs and the public’s and the

media’s substantial First Amendment interest

in timely access to court filings.

Id. As a result, the Seventh Circuit found that the district

court should have abstained from exercising subject

matter jurisdiction over CNS’s complaint due to principles

of equity, comity and federalism. Id. at 1071.

CNS contends that in reaching this conclusion, the

Seventh Circuit primarily relied upon SKS. (Pet. 9.) The

Seventh Circuit did rely upon SKS but it also relied upon

the decisions of this Court in O’Shea and Rizzo. Brown,

908 F.3d at 1071-73.

The Seventh Circuit stated that this Court “has

recognized four principal categories of abstention:

Pullman, Burford, Younger, and Colorado River.” Id.

at 1071; see also Colo. River Water Conservation Dist.

v. United States, 424 U.S. 800 (1976); Younger, 401 U.S.

37; Burford v. Sun Oil Co., 319 U.S. 315 (1943); R.R.

15

Comm’n of Tex. v. Pullman Co., 312 U.S. 496 (1941). The

Court noted that “[t]wo additional categories, O’Shea and

Rizzo, can be considered extensions of Younger” and that

“Younger, with its extension in O’Shea and Rizzo, is most

closely applicable to the present case; however, it is not

a perfect fit, and we ultimately base our decision on the

more general principles of federalism that underlie all of

the abstention doctrines.” Brown, 908 F.3d at 1071.

O’Shea concluded “that comity and federalism

‘preclude[d] equitable intervention’ because the plaintiffs

sought ‘an injunction aimed at controlling or preventing the

occurrence of specific events that might take place in the

course of future state criminal trials.’” Id. at 1072 (citing

O’Shea, 414 U.S. at 499-500). Rizzo “further extended the

principles of Younger to limit federal court review of local

executive actions.” Id. (citing Rizzo, 423 U.S. at 366). In

Rizzo, the plaintiff filed claims for injunctive relief alleging

that the internal procedures of the Philadelphia police

department led to the mistreatment of minority civilians

in violation of the Constitution. Rizzo, 423 U.S. at 36667. The district court required city officials to come up

with a “comprehensive program” for dealing with civilian

complaints pursuant to the court’s detailed guidelines. Id.

at 364-66, 369-70. This Court reversed. Id. at 366.

O’Shea and Rizzo abstention prohibit the exercise of

federal subject matter jurisdiction where doing so would

require the federal courts to oversee the operation of state

courts and state executive offices. See Brown, 908 F.3d at

1072-73. As the Seventh Circuit noted:

While the district court’s order in the present

case does not map exactly on the orders in

16

O’Shea and Rizzo, it would also impose a

significant limit on the state courts and their

clerk in managing the state courts’ own affairs.

Against the backdrop of Younger, O’Shea, and

Rizzo, we find that CNS’s request for federal

intrusion at this stage of the dispute between

CNS and the [Circuit] Clerk calls for abstention.

Id. at 1073.

It is true, as the Seventh Circuit observed in Brown,

that the Ninth Circuit reached the opposite conclusion on

the application of O’Shea abstention in Courthouse News

Service v. Planet, 750 F.3d 776 (9th Cir. 2014). Id. at 1074.

Planet, however, is an outlier and does not provide a basis

for granting CNS’s petition for a writ of certiorari. While

Brown and Planet reach opposite conclusions regarding

the application of O’Shea and Rizzo abstention to a

First Amendment claim for immediate access to newly

filed complaints, CNS also claims that Brown conflicts

with a Second Circuit decision, Hartford Courant Co. v.

Pellegrino, 380 F.3d 83 (2nd Cir. 2004). It does not.

REASONS FOR DENYING THE PETITION

The Petition should be denied for four reasons:

First, it is far from clear that Planet is the law of the

Ninth Circuit with regard to the application of O’Shea and

Rizzo abstention. While Planet attempted to distinguish

an earlier Ninth Circuit case, E.T. v. Cantil-Sakauye, 682

F.3d 1121 (9th Cir. 2012), it did not do so persuasively.

See Planet, 750 F.3d at 790. Beyond that, one year after

Planet, the Ninth Circuit decided Miles v. Wesley, 801

17

F.3d 1060 (9th Cir. 2015). In Miles, the Ninth Circuit

followed E.T. and, under O’Shea, abstained from enjoining

the California Supreme Court from reducing the number

of courthouses used for unlawful detainer actions. Miles,

801 F.3d at 1066. The tension within the Ninth Circuit’s

own jurisprudence weakens the alleged circuit split that

CNS claims to exist.

Second, the Second Circuit case that CNS cites—

Hartford Courant —neither considers nor discusses

O’Shea or Rizzo. See generally Hartford Courant, 380 F.3d

83. Planet relied upon Hartford Courant with respect to

the application of Pullman abstention, an issue that is not

before the Court here. Planet, 750 F.3d at 789. In addition,

the Second Circuit recently decided Disability Rights New

York v. New York, 916 F.3d 129 (2nd Cir. 2019), a case that

follows Brown with respect to the application of O’Shea

abstention. CNS’s claim that a circuit split exists between

the Second and Seventh Circuits regarding Brown or

O’Shea is meritless.

Third, the narrow issue before the Court is one of

abstention, federalism and comity. The fact that the merits

present a First Amendment question does not weigh any

more in favor of this Court’s review than any other federal

question. Even if that were an appropriate consideration,

the fact that the public may view the vast majority of

complaints within a day of their filing cuts against CNS’s

attempt to magnify the importance of the merits of this

case and the need for immediate review now.

Fourth, Brown was correctly decided. A contrary

result violates comity and disrespects Illinois’ authority to

manage its own courts. Whether or not Planet is the law

18

of the Ninth Circuit, it is definitely an island unto itself.

It is Brown that properly follows and applies Younger,

O’Shea and Rizzo.

I.

It Is Unclear Whether Planet Is The Law of The

Ninth Circuit Regarding The Proper Application

of O’Shea and Rizzo.

(Response to CNS’s Petition at 10-12.)

CNS’s Petition rests on the premise that Planet is the

law of the Ninth Circuit. That premise is far from certain.

Pursuant to O’Shea and Pullman, the district court

in Planet abstained from exercising subject matter

jurisdiction over CNS’s First Amendment lawsuit

against Michael Planet, the Clerk of the Ventura County,

California Superior Court. Planet, 750 F.3d at 782. On

appeal, the panel reversed the district court’s decision and

held that CNS could bring a First Amendment claim in the

district court alleging that the Ventura County Superior

Court’s purported failure to provide same day access

to newly filed unlimited civil complaints violated CNS’s

right of access to public judicial proceedings under the

First Amendment. Id. at 792. In reaching this conclusion,

the panel in Planet rejected the application of both the

Pullman and the O’Shea/Rizzo abstention doctrines. Id.

at 783, 792. The Ninth Circuit panel in E.T. applied O’Shea

and Rizzo in a far different manner than Planet did. See

E.T., 682 F.3d at 1125.

In E.T., the plaintiffs were foster children who

brought a putative class action against state and county

judicial officials, alleging that the caseloads of the county

dependency court and court-appointed attorneys were

19

so excessive as to violate the Due Process Clause and

other federal law. Id. at 1122. The district court granted a

motion to dismiss, finding that it was required to abstain

under O’Shea. Id. at 1123. The Ninth Circuit affirmed.

Id. at 1122.

Following O’Shea and Rizzo, the E.T. panel declined

the plaintiffs’ “invitation to consider in isolation their

(now-narrowed) request for relief, as though reaching the

merits of their declaratory judgment claims would end the

matter. For ‘even the limited decree’ sought here ‘would

inevitably set up the precise basis for future intervention

condemned in O’Shea.’” Id. at 1125. (emphasis omitted)

Perhaps recognizing its potential inconsistency

with E.T., Planet attempted to distinguish the differing

application of O’Shea and Rizzo in the two Ninth Circuit

cases. Planet, 750 F.3d at 790. Citing E.T., Planet observed

that “O’Shea compels abstention where the plaintiff seeks

an “ongoing federal audit” of the state judiciary, whether

in criminal proceedings or in other respects.” Id. Planet

then concluded—incorrectly—that CNS’s lawsuit against

the Ventura County Superior Court did not require an

“ongoing federal audit” and, thus, O’Shea abstention did

not apply. Id. at 791.

Just one year after Planet, the Ninth Circuit decided

Miles. In Miles, the plaintiffs filed a class action challenge

to the consolidation of unlawful detainer actions into hub

courts. The district court dismissed the suit pursuant

to O’Shea abstention and the Ninth Circuit affirmed,

finding that the plaintiffs sought the precise type of

federal interference with sensitive state activities such

as the administration of the judicial system that O’Shea

prohibited. Miles, 801 F.3d at 1064.

20

The underlying interest in preserving the balance

between federal equitable relief and state administration

of its own courts in E.T., Miles and O’Shea is the same

interest in play in Planet and in this case as well. Ensuring

compliance with a federally ordered deadline for publication

of complaints would be akin to an “ongoing federal audit”

of court operations, not a one-time intervention, because it

would require hair-splitting as to the appropriate speed of

publication, and ongoing monitoring to ensure the Circuit

Clerk’s compliance. O’Shea, 414 U.S. at 500. Granting

certiorari based on an alleged split between the Seventh

and Ninth Circuits would be imprudent if the law of Ninth

Circuit was not settled.

With respect to the application of O’Shea and the

determination of when federal oversight of the state

judicial system becomes “an ongoing federal audit,”

Planet, E.T. and Miles are difficult if not impossible to

reconcile. O’Shea, 414 U.S. at 500. The Ninth Circuit, to be

sure, has not yet attempted to resolve these issues through

an en banc hearing. As Justice Sotomayor has observed,

“[w]hen that sort of internal division exists, the ordinary

course of action is to allow the court of appeals the first

opportunity to resolve the disagreement” and not for this

Court to grant certiorari. Carlton v. United States, 135

S. Ct. 2399, 2401 (2015) (Sotomayor, J., respecting denial

of the petition for writ of certiorari).

With the three Ninth Circuit precedents in conflict,

the best approach would be “to allow the court of appeals

the first opportunity to resolve the disagreement” and not

for this Court to grant certiorari. Id.

21

II. The Second Circuit Recently Followed Brown.

(Response to CNS’s Petition at 9, 11, 16-20.)

CNS’s claim that Brown conflicts with the law of the

Second Circuit is doubly wrong: (1) on the issue of O’Shea

abstention, Hartford Courant does not conflict with

Brown and (2) a little over three months ago, the Second

Circuit decided Disability Rights New York, a case where

the Second Circuit followed O’Shea and Brown.

In contrast to Disability Rights New York, the Second

Circuit opinion in Hartford Courant did not discuss

O’Shea but rather Pullman abstention. See Hartford

Courant, 380 F.3d at 100. In Hartford Courant, the Second

Circuit held that Pullman abstention did not bar federal

subject matter jurisdiction over a First Amendment claim

challenging the Connecticut court system’s longstanding

practice of sealing docket sheets in certain civil cases. Id.

The Second Circuit found that the Pullman doctrine did

not apply for two reasons: “first, because there was ‘no

applicable state statute’ construction of which would avoid

the constitutional issues, and second, because ‘the weight

of the First Amendment issues involved counsels against

abstaining.’” Planet, 750 F.3d at 787 (citing Hartford

Courant, 380 F.3d at 100). Significantly, Hartford Courant

did not discuss O’Shea or Rizzo abstention. See generally

Hartford Courant, 380 F.3d 83.

In rejecting the application of Pullman abstention,

Planet relied upon the Second Circuit’s decision in

Hartford Courant. Planet, 750 F.3d at 787-89. However,

in declining to apply O’Shea abstention, Planet neither

discussed nor relied on Hartford Courant. Id. at 789-92.

22

In contrast to Hartford Courant, Disability Rights

New York discussed and applied O’Shea abstention to bar

a claim against the State of New York, its court system,

and its Chief Judge and Chief Administrative Judge

regarding the manner in which guardianship proceedings

are conducted. Disability Rights New York, 916 F.3d at

133-36. The district court and the Second Circuit both

held that the exercise of federal jurisdiction would be “a

continuing, impermissible ‘audit’ of New York Surrogate’s

Court proceedings” and thus fell within the ambit of

O’Shea abstention. Id. at 133, 136.

Moreovoer, the Second Circuit found that the plaintiffs’

lawsuit against New York, its court system, and its Chief

Judge and Chief Administrative Judge was similar to

CNS’s lawsuit and the Circuit Clerk. Id. at 134. And just

like the Second Circuit in Disability Rights New York,

the Seventh Circuit in Brown followed O’Shea in order

to prevent continuing federal oversight of the way Illinois

courts process newly e-filed civil complaints. Brown held

that CNS’s requested relief:

would likely lead to subsequent litigation in the

federal courts. We want to avoid a situation in

which the federal courts are dictating in the

first instance how state court clerks manage

their filing procedures and the timing of press

access. We also want to avoid the problems

that federal oversight and intrusion of this sort

might cause.

Brown, 908 F.3d at 1075 (footnote omitted).

With respect to Brown and O’Shea, the Second and

Seventh Circuits are in harmony.

23

III. Planet Is an Outlier and Does Not Create a

Sufficient Enough Split Among The Circuits to

Warrant The Granting of CNS’s Writ of Certiorari.

(Response to CNS’s Petition at 10-20, 27-32.)

The holdings in Planet and Brown are in conflict with

each other but Brown is in harmony with O’Shea and

Rizzo, as well as cases from the Second, Sixth, Eighth and

Ninth Circuits. See Disability Rights New York, 916 F.3d

at 131, 136; Oglala Sioux Tribe v. Fleming, 904 F.3d 603,

612 (8th Cir. 2018) (abstaining under O’Shea from enjoining

allegedly unconstitutional child custody proceedings

because “[t]he relief requested would interfere with the

state judicial proceedings by requiring the defendants

to comply with numerous procedural requirements” and

“failure to comply with the district court’s injunction

would subject state officials to potential sanctions”); Miles,

801 F.3d at 1066; E.T., 682 F.3d at 1124; Kaufman v. Kaye,

466 F.3d 83, 86 (2d Cir. 2006) (abstaining under O’Shea

from enjoining internal state court judicial assignment

procedures); Parker v. Turner, 626 F.2d 1, 8 (6th Cir. 1980)

(holding that Younger abstention barred a federal claim

which effectively asked the district court to monitor “the

manner in which state juvenile judges conducted contempt

hearings in non-support cases”).

Planet read O’Shea too narrowly and was not faithful

to the application of Younger abstention in O’Shea.

Planet drew a distinction between federal intrusion into

state court procedure and federal intrusion into state

processing of the filing of civil complaints. Planet, 750

F.3d at 792. This is a distinction without a difference. In

any event, Planet’s narrow reading of O’Shea cannot be

squared with precedent from this Court or other Circuits.

24

O’Shea concerns federal interference with state court

practices based upon constitutional grounds. O’Shea,

414 U.S. at 491-92. In O’Shea, the plaintiffs sought to

enjoin state judges from discriminating against AfricanAmericans in certain criminal court proceedings. Id.

In holding that the district court should have abstained

from hearing the class claims, this Court recognized that

abstention doctrines are not limited to federal lawsuits

that interfere with ongoing state proceedings, as was the

case in Younger. Id. at 501. O’Shea extended Younger to

hold that “an injunction aimed at controlling or preventing

the occurrence of specific events that might take place

in the course of future state criminal trials” amounted

to “nothing less than an ongoing federal audit of state

criminal proceedings which would indirectly accomplish

the kind of interference that Younger . . . sought to

prevent.” Id.at 500.

Importantly, O’Shea further held that abstention is

appropriate to prevent federal courts from becoming

monitors of state-court operations: “[m]onitoring of the

operation of state court functions . . . is antipathetic to

established principles of comity,” and amounts to “a

major continuing intrusion of the equitable power of the

federal courts into the daily conduct of state criminal

proceedings,” which would sharply conflict “with the

principles of equitable restraint….” Id. at 501-02 (citation

omitted); accord Rizzo, 423 U.S. at 378-80 (following

O’Shea and holding that the district court should have

abstained from deciding a motion for a motion for

mandatory injunction to direct the Philadelphia police

department to draft comprehensive internal procedures

to address civilian complaints).

25

Under O’Shea, constitutional concerns about state

court practices should be advanced in state court. As

O’Shea observed:

Respondents do not seek to strike down a single

state statute, either on its face or as applied

. . . What they seek is an injunction aimed at

controlling or preventing the occurrence of

specific events that might take place in the

course of future state criminal trials.

O’Shea, 414 U.S. at 500. Indeed, just as CNS’s challenge

to the Circuit Clerk’s practice of performing the “accept/

reject” function was a challenge to a state court practice,

the constitutional challenges in O’Shea and its progeny

have been challenges to state court practices.

CNS cites Sprint Communications, Inc. v. Jacobs,

571 U.S. 69 (2013) and New Orleans Public Service, Inc.

v. Council of New Orleans, 491 U.S. 350 (1989)—two cases

that neither discuss nor apply O’Shea or Rizzo —in support

of its argument that the Seventh Circuit improperly

applied O’Shea and Rizzo abstention in Brown. (Pet.

21-23.) Neither Sprint nor New Orleans Public Service

addressed the issue of whether abstention is required to

prevent ongoing federal interference and oversight over

state court practices and procedures.

In Disability Rights New York, the Second Circuit

distinguished Sprint and New Orleans Public Service, as

both cases addressed situations where the federal court

was asked to enjoin ongoing state and federal proceedings.

Disability Rights New York, 916 F.3d at 133-134. The

Second Circuit noted that this Court “has also held that

26

even where no state proceedings are pending, federal

courts must abstain where failure to do so would result in

‘an ongoing federal audit of state criminal proceedings.’”

Id. at 134 (citing O’Shea, 414 U.S. at 500). Indeed, the

Second Circuit stated that “the considerations underlying

Younger are still very much at play even when a suit is

filed prior to the onset of state proceedings.” Id.

Sprint and New Orleans Public Service are inapposite

and do not support CNS’s argument that Brown is

contrary to established law.

IV. Brown Was Correctly Decided.

(Response to CNS’s Petition at 10-12, 20-27.)

CNS argues that the decision below was wrong. (Pet

20.) Not so.

As an initial matter, when she followed the Standards

and Order 2014-02, the Circuit Clerk simply discharged

her duties. 5 Pursuant to ¶¶2(c) and 3 of Order 2014-02,

the Circuit Clerk implements the State court’s policy on

electronic filing: i.e., reviewing electronically submitted

complaints before determining whether to reject or accept

such complaints as properly filed. A review of Order 20145. Circuit court clerks in Illinois are the highest non-judicial

members of the state judiciary. See Drury v. County of McLean,

433 N.E.2d 666 (Ill. 1982). The Circuit Clerk’s purpose is to keep

an accurate and reliable record of county circuit court proceedings

for the judiciary, litigants and the public, 705 ILCS 105/13 (2019),

and to execute judicial orders. Failure to follow judicial orders

would likely be contemptuous. See In re Swan, 415 N.E.2d 1354,

1361 (Ill. App. Ct. 1981) (affirming an order holding respondent in

contempt for his refusal to obey a trial court order).

27

02 shows that it is highly germane to this appeal. ¶2(c) of

Order 2014-02 sets forth a list of documents that may not

be electronically filed:

• documents containing confidential information as

specified in Supreme Court Rule 15;

• documents containing personal identity information

as specified in Supreme Court Rule 138;

• documents containing the identity of individuals

contained in repor ts made pursuant to the

Communicable Disease Report Act, 745 ILCS 45/1;

• reports relating to an individual’s disability

pursuant to the Illinois Income Tax Act, 35 ILCS

5/917(a)(ii);

• confession of judgment;

• documents required by law, rule, or order to be filed

and maintained in their original form;

• petition for marriage license by an underage

petitioner;

• petition for an order of protection, no contact order,

or stalking no contact order;

• registration of Illinois court judgment;

• registration of administrative judgment;

28

• discovery materials excluded pursuant to Illinois

Supreme Court Rule 201; and

• any document when the individual document or the

entire case is impounded or sealed by law, rule, or

order.

(R. 19-2, ¶2(c).) Order 2014-02, ¶2(d) lists the types of

cases for which parties may not make electronic filings:

(1) adoption, (2) emancipation of a minor, (3) eminent

domain, (4) fictitious vital records pursuant to the Vital

Records Act, 410 ILCS 535/15.1 (2019), (5) juvenile court,

(6) mental health, (7) ordinance violations, (8) proceedings

pursuant to the Illinois Sexually Transmissible Disease

Control Act, 410 ILCS 325/1 (2019), (9) petition for judicial

waiver of notice under the Parental Notice of Abortion

Act of 1995, 750 ILCS 70/1 (2019) and (10) any other type

of case required to be impounded or sealed by law, rule,

or order. (Id., ¶2(d).)

Paragraph 3(c) of Order 2014-02 (“Paragraph 3(c)”)

states that “[a]ny document submitted electronically shall

be considered filed with the [Circuit] Clerk’s Office if not

rejected by the Clerk’s Office.” (Id., ¶3(c).) This paragraph

shows that the Circuit Clerk is responsible for declining

to accept documents that are improperly submitted

electronically.

The Seventh Circuit found that Illinois required the

Circuit Clerk to perform the accept/reject function before

making a newly e-filed civil complaint available to the

public. Brown, 908 F.3d at 1066, n. 2. But the Seventh

Circuit also recognized that the Illinois courts are best

equipped to answer that question. Id. In any event,

29

the Circuit Clerk could not perform the accept/reject

function and comply with the district court’s preliminary

injunction. This posed a knotty legal problem, one that the

Seventh Circuit solved by following and applying O’Shea

and Rizzo abstention. As a result, the Seventh Circuit

held that CNS’s “temporal access dispute with a state

court clerk” should be heard in an Illinois court where

CNS could advance its constitutional claims and where

the court could rule on the Circuit Clerk’s duty to perform

the accept/reject function. Id. at 1075.

Brown properly followed O’Shea and Rizzo and is

consistent with the Second Circuit’s decisions in Disability

Rights New York and Kaufman, the Sixth Circuit’s

decision in Parker, the Seventh Circuit’s decision in SKS,

and the Ninth Circuit’s decision in E.T. and Miles. Planet

is an outlier. It is not necessary for this Court to review

Brown.

Nonetheless, CNS argues at length that Brown did

not follow the federal courts’ “virtually unflagging”

obligation to decide cases. (Pet. 24-25.) This argument,

however, ignores the proverbial elephant in the room:

federalism requires federal courts to abstain from

exercising jurisdiction when doing so “would intrude upon

the independence of the state courts.” Brown, 908 F.3d at

1071 (citing SKS, 619 F.3d at 677).

CNS also argues that it has advanced a right of

access claim under the First Amendment and, as a result,

the application of O’Shea and Rizzo abstention is not

appropriate. This Court, however, has never read a First

Amendment exception into Younger, O’Shea or Rizzo

abstention. The plaintiffs in O’Shea filed claims under

30

the First, Sixth, Eighth, Thirteenth and Fourteenth

Amendments. O’Shea, 414 U.S. at 490. The nature of

their claims did not factor into the propriety of applying

Younger abstention and the nature of CNS’s claim here

is also of no moment.

Brown was correctly decided and CNS has failed to

establish any need for immediate review of this decision.

CONCLUSION

The petition for writ of certiorari should be denied.

Respectfully submitted,

Cathy McNeil Stein

Kimberly M. Foxx

Assistant State’s Attorney

Cook County State’s

Chief, Civil Actions Bureau

Attorney

500 Richard J. Daley Center

Paul A. Castiglione*

Chicago, Illinois 60602

Prathima Yeddanapudi

(312) 603-2350

Assistant State’s Attorneys

paul.castiglione

Counsel for Respondent

@cookcountyil.gov

Of Counsel

* Counsel of Record