Patrykus v. Gomilla
United States District Court for the Northern District of Illinois
121 F.R.D. 357 (1988)

- Written by Mary Phelan D'Isa, JD
Facts
Allen Patrykus, Richard Babel, and Joe Doe (plaintiffs) brought a civil-rights action for declaratory and injunctive relief and for damages against agents of the Northeastern Metropolitan Group (NEMEG), an inter-governmental drug-enforcement agency, and officers of the Chicago Police Department. The class representatives sought to certify a class that was comprised of all persons who were subjected to unlawful seizures, detentions, searches, and interrogations during the agents’ and officers’ raid of Carol’s Speakeasy in Chicago on September 12, 1985. The class representatives argued that the class met all the requirements for class certification under Federal Rule of Civil Procedure 23(a). The agents and officers contested class certification and argued that the class representatives failed to allege that the proposed class was geographically dispersed. The class representatives argued that the potential stigma associated with bringing a claim for a raid in a gay bar would likely discourage potential class members from suing individually or even in their own names.
Rule of Law
Issue
Holding and Reasoning (Conlon, J.)
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