U.S. Rep. Jesus "Chuy" Garcia has withstood a lawsuit from one-time candidate for Chicago city alderman Jaime Guzman, who claimed Garcia, to boost Garcia's chosen candidate in the aldermanic race, had allegedly spread a false rumor that Guzman had domestically abused the woman who would later become Guzman's wife.
On March 29, a three-justice panel of the Illinois First District Appellate Court sided with Garcia in the dispute, refusing Guzman's attempt to revive his defamation claims against the politically powerful congressman.
Guzman had sued Garcia in 2020, claiming the congressman had smeared his name, allegedly using information Guzman had revealed to him in private, as part of an initial bid to secure Garcia's political support in an expected tough campaign for alderman in Chicago's 14th Ward.
That seat had been held for decades by the formerly ultra powerful Ald. Ed Burke, who ruled the city's Finance Committee and led the Cook County Democratic Party. Burke has since left the City Council and was convicted earlier this year on political corruption and extortion charges.
In 2019, Guzman was one of two candidates to make it to Election Day against Burke.
According to court documents, Guzman in 2017 sought the endorsement of Chuy Garcia, with whom Guzman claims to have worked closely politically for years before the aldermanic race.
During their conversations, Guzman allegedly revealed to Garcia - and only Garcia - that in 2007, Chicago Police had filed a report stemming from a fight he had with his then-girlfriend, who is now Guzman's wife. According to court documents, Guzman was never arrested or charged with domestic violence or any other crime from that incident or any others.
Garcia eventually endorsed a different candidate, Tanya Patiño. Patiño had also received the endorsement of other progressive activists, notably including Jose Luis Torrez, a community organizer who had dropped out of the race in the 14th Ward.
However, according to the complaint, Guzman learned that Torrez had allegedly told others not to vote for Guzman because he "had a criminal record for committing ‘domestic violence’ against his wife.”
According to the complaint, after Garcia allegedly pressed Torrez to drop out of the race and support Patiño, others allegedly began to repeat the false rumor about Guzman.
After Guzman lost the race to Burke, he filed suit against Garcia, Torrez and two others, accusing them of defamation.
Cook County Circuit Judge Karen L. O’Malley dismissed Guzman's lawsuit, saying he could not prove the defendants had "published" the reputation-wrecking rumor, as required by law.
Guzman appealed, seeking to revive his claim against Garcia.
On appeal, Guzman asserted he believed Garcia could be the only possible source for the allegedly false rumor, as Guzman noted he had told only Garcia, in private, about the 2007 police incident report.
The appellate justices, however, said that assertion does not lead to a firm enough conclusion to allow Guzman to continue with his lawsuit against the congressman.
The decision was authored by Justice Nathaniel Howse, with concurrence from justices Margaret Stanton-McBride and David W. Ellis. The decision was issued as an unpublished order under Supreme Court Rule 23, which limits its use as precedent.
"Plaintiff’s (Guzman's) 'circumstantial facts' come down to this: Plaintiff was a political rival of defendant (Garcia), so defendant spread a false rumor to hurt plaintiff’s political campaign; and it had to be defendant who started the rumor because he was the only person plaintiff told about the incident report and defendant was motivated to harm plaintiff because of the political campaign," Howse wrote.
"Accepting that as fact, we cannot say we have no doubt that plaintiff is correct."
They said they agreed with Garcia that it is possible, if not likely, that as a result of Guzman's entry into the political ring, other people besides Garcia may have learned of the existence of the 2007 police incident report.
In short, they said, Guzman has fallen far short of proving Garcia was the originator of the rumor, or that Garcia ever told anyone about the police report, much less accused Guzman of domestic violence.
"There are any number of sources of the information that plaintiff 'believes' is the precursor to the rumor," Howse wrote. "The report may not even be a source of the rumor. It could be any individual knowledgeable of the events that led to the incident report including friends, family members, or neighbors.
"Once this fact is called into question, all of plaintiff’s beliefs become a house of cards that falls short of erasing any question about the veracity of plaintiff’s beliefs," Howse wrote in the decision.