Bless v. Cook County Sheriff's Office

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ROBERT BLESS, ) ) Plaintiff, ) ) v. ) No. 13 C 4271 ) COOK COUNTY SHERIFF’S OFFICE, ) Judge John Z. Lee TOM DART in his official and individual ) capacity; DEWAYNE HOLBROOK; ) JOSEPH WAYS, SR.; ZELDA WITTLER, ) SHERYL COLLINS; EDWARD DYNER; ) HENRY HEMPHILL; ROSEMARIE ) NOLAN; COOK COUNTY SHERIFF’S ) MERIT COMMISSION; COOK COUNTY, ) a unit of local government, ) ) Defendants. ) MEMORANDUM OPINION AND ORDER The de facto officer doctrine has existed for over a century in common law, but its development in…