Quinton Cooley, the plaintiff-appellant, filed a lawsuit against Amita St. Francis Hospital of Evanston and John Does 1-10 (inclusive defendant), in the Appellate Court of Illinois, First District. The court case ID is No. 1-23-1479 and the order was filed on April 30, 2024. Cooley accused the defendants of gross negligence and false imprisonment.
Representing himself, Cooley alleged that during his visit to the hospital for back pain treatment on an unspecified date, he was wrongfully accused of self-harm by the hospital staff. He further claimed that he was physically assaulted, given injections without informed consent, choked, and falsely imprisoned for four days. The exact dates of these alleged incidents were not provided in his complaint. However, a letter from the Illinois Guardianship and Advocacy Commission dated October 2, 2019, attached to his complaint suggested that these events might have occurred in 2019.
The defendants moved to dismiss Cooley's complaint citing failure to provide specific factual allegations regarding when the alleged events occurred and lack of documentation supporting his allegations of medical negligence. They also argued that if the incidents took place in 2019 as suggested by the attached letter, then Cooley's complaint filed in 2022 was time-barred by the two-year statute of limitations applicable to personal injury cases.
Cooley sought compensatory damages for economic and noneconomic damages caused by treatment costs and pain and suffering he experienced due to these alleged incidents. Despite being granted leave to file an amended complaint with specific dates and supporting documentation by April 27, 2023, Cooley's amended complaint still lacked sufficient evidence. Consequently, his cause of action was dismissed with prejudice as it was time-barred by the two-year statute of limitation period.
Justices Cobbs, McBride and Ellis all concur that since the plaintiffs allegations of action occurred on August 20th, 2019, the two-year statute of limitations procedurally bars plaintiff's claims. The circuit court did not err in dismissing the plaintiffs amended complaint with prejudice. For that reason the circuit court judgment is affirmed.