On February 22, 2025, Plaintiff Juan Manzanares was arrested by officers from the Spring Valley Police Department. Manzanares was handcuffed in front and placed in the backseat of a law enforcement vehicle driven by Defendant Michael Oslanzi. Before taking Manzanares to the Bureau County Jail for medical clearance, Oslanzi drove him to a hospital.
At the hospital, Manzanares alleges that Oslanzi attempted to escort him from the backseat of the SUV by putting him into a headlock, grabbing him by his handcuffs, and violently pulling him out of the vehicle. Manzanares claims this caused him to land unprotected on his left shoulder onto the pavement, resulting in a torn rotator cuff and injuries to his hands and wrists.
Manzanares required shoulder surgery and extensive physical therapy, could not continue working as a machinist, and sought damages for physical and emotional pain, lost wages, and medical bills. His complaint brings three counts: Fourth Amendment excessive force under § 1983 against Oslanzi, battery under Illinois law against the City of Spring Valley, and indemnification under Illinois law against the city.
Defendants jointly filed a motion to dismiss all counts, attaching seven videos to their motion and moving for leave to file four of the exhibits under seal. They also moved for leave to file a reply, which Judge Sara Darrow denied as unnecessary because Manzanares’s arguments were not unexpected.
In ruling on the motion to dismiss, Judge Darrow determined that the video exhibits were not referenced in the complaint and did not fit the narrow incorporation-by-reference doctrine. She rejected Defendants’ argument that recent case law extended the doctrine to cover video footage not attached to or referenced in the complaint, noting that Seventh Circuit precedent still requires exhibits to be referenced in the pleading.
Judge Darrow exercised her discretion to decline converting the motion to dismiss into one for summary judgment, noting that discovery may provide additional factual context helpful to the court. Because Defendants’ arguments for dismissal rested entirely on video footage the court was not considering, she denied the motion to dismiss.
Defendants are directed to file an answer to the complaint within fourteen days. The court’s decision leaves Manzanares’s claims intact for further litigation and discovery.