Illinois
How Adickes v. S.H. Kress & Co. applies in Illinois: state-specific rules, key cases, and bar exam notes for Other.
Illinois law similarly recognizes the fundamental principles of equal protection and deliberate indifference as articulated in Adickes v. S.H. Kress & Co. Illinois courts have focused on the ability to prove a state actor's complicity in discriminatory actions and the necessity of showing clear evidence of a policy or custom that violates an individual's rights.
In Illinois, a plaintiff must demonstrate that a state actor was deliberately indifferent to the constitutional rights of an individual in a manner akin to federal standards established in Adickes.
The Illinois Supreme Court held that state actors could be liable under Section 1983 if they demonstrated a policy or custom facilitating discrimination.
The court ruled that the city could be held liable for failing to act on known instances of discrimination by its employees, echoing principles from Adickes.
The Illinois appellate court found that inadequate training of police officers constituted a policy of indifference to civil rights violations.
Illinois law applies the same federal standards set forth in Adickes regarding the state’s obligation to prevent civil rights violations. However, Illinois courts may emphasize the specific state context and the necessity of demonstrating a clear policy or custom more so than federal courts.
Principles from Adickes often appear in the Illinois bar exam, particularly in civil rights and torts sections, where the intersection of state action and constitutional rights will be tested.