Case: 1:13-cv-07572 Document #: 122 Filed: 10/24/16 Page 1 of 5 PageID #:590 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION MOISES MORALES, et al., ) ) Plaintiffs, ) ) Case No.: 13-cv-07572 vs. ) ) Hon. Amy J. St. Eve ) CRAIG FINDLEY, et al., ) ) Defendants. ) JOINT MOTION FOR PRELIMINARY APPROVAL OF PROPOSED SETTLEMENT AGREEMENT Pursuant to Rule 23(e) of the Federal Rules of Civil Procedure, the Parties jointly move the Court to issue an order (1) granting preliminary approval to the proposed Settlement Agreement, pending a final fairness hearing, (2) approving the attached Proposed Notice of Settlement, and (3) setting dates for a fairness hearing and a deadline for objections to the settlement, to be filed with the Court. In support of this motion, the Parties state as follows: 1. On October 22, 2013, the named plaintiffs filed this lawsuit on behalf of themselves and on behalf of a putative class comprised of the men and women who, while on parole/mandatory Supervised Release ( MSR ), are supervised by the Illinois Department of Corrections ( IDOC ) and who now or in the future will be subject to parole revocation proceedings conducted by the IDOC and the Illinois Prisoner Review Board ( PRB ). The Plaintiffs complaint alleged that the Defendants, which include the Chairman of the Prisoner Review Board and the Director of the Illinois Department of Corrections, violated Plaintiffs rights under the Due Process Clause of the Fourteenth Amendment to the United States Constitution. The Plaintiffs alleged that the Defendants fail to hold parole revocation hearings 1
Case: 1:13-cv-07572 Document #: 122 Filed: 10/24/16 Page 2 of 5 PageID #:591 that comport with the requirements of procedural due process, including by denying parolees the right to examine the evidence against them and the right to confront witnesses during preliminary and final parole revocation proceedings. The Plaintiffs also alleged that the Defendants fail to provide parolees with appointed counsel during preliminary and final parole revocation proceedings. The Plaintiffs sought to obtain injunctive relief on behalf of the putative class. 2. Shortly after the filing of the suit, the Parties began settlement negotiations and the court stayed discovery. In February 2015, the Parties reached an impasse in their negotiations and requested that this court lift the discovery stay. At this point, the Parties engaged in significant discovery, including 12 depositions of the Defendants representatives, the production of thousands of pages of documents, interviews with putative class members and observations of dozens of parole hearings. Before the close of expert discovery, in February 2016, the Parties reengaged in settlement talks. These negotiations culminated in the proposed Settlement Agreement, attached hereto as Exhibit A. 3. The Settlement Agreement complies with the requirements of Fed. R. Civ. P. 23(e), under which the Court may grant approval of a settlement only after finding that it is fair, reasonable, and adequate. In determining whether to approve a settlement, the Court considers the following factors: the strength of plaintiffs case compared to the amount of defendants settlement offer, an assessment of the likely complexity, length and expense of the litigation, an evaluation of the amount of opposition to settlement among affected parties, the opinion of competent counsel, and the stage of the proceedings and the amount of discovery completed at the time of settlement. Synfuel Technologies, Inc. v. DHL Express (USA), Inc., 463 F.3d 646, 653 (7th Cir. 2006) (quoting Isby v. Bayh, 75 F.3d 1191, 1199 (1996)) (internal quotation marks 2
Case: 1:13-cv-07572 Document #: 122 Filed: 10/24/16 Page 3 of 5 PageID #:592 omitted). Courts have also considered the presence of collusion in reaching the settlement and whether the agreement promotes the public interest as relevant factors. See ACLU v. U.S. General Services Admin., 235 F. Supp. 2d 816, 818 (N.D. Ill. 2002). 4. Applying the factors to this case, the proposed Settlement Agreement directly remedies the alleged constitutional violations set forth in the Plaintiffs complaint; the Settlement Agreement prevents protracted and expensive litigation of the case, while preserving State resources for use in the implementation of the proposed agreement; there is likely to be little opposition to the Settlement Agreement from class members; counsel for the parties, and in particular class counsel, believe the Settlement Agreement to be a fair and adequate resolution of the class claims; in seeking settlement, the parties zealously pursued negotiations, which were at arms-length, non-collusive, and informed by the extensive discovery the parties engaged in before finalizing this agreement; and the proposed settlement clearly promotes the public interest. 5. In accordance with Rule 23(e)(1), the Parties also propose a Notice of Settlement, attached as Exhibit B, which will apprise putative class members of the lawsuit, class certification, and the proposed Settlement Agreement, and provide class members information pertaining to the scheduled fairness hearing, as well as their opportunity to object to the Settlement Agreement. The Parties propose multiple methods of distribution of notice, which will include posting the notice prominently in IDOC facilities and providing a copy to each parolee who leaves IDOC custody during the notice period. Additionally, Plaintiffs counsel proposes to hold a number of focus groups with putative class members to inform them about the settlement and to assist in the process of gathering any objections/statements of support. 3
Case: 1:13-cv-07572 Document #: 122 Filed: 10/24/16 Page 4 of 5 PageID #:593 CONCLUSION For the foregoing reasons, the Parties respectfully request that this Court enter an order (1) granting preliminary approval to the proposed Settlement Agreement, pending a final fairness hearing; (2) approving the attached Proposed Notice of Settlement; and (3) setting dates for (a) a deadline for objections to or comments on the settlement, (b) the filing with the Court of any objections to or comments on the settlement and the Parties responses to those objections or comments, and (c) a fairness hearing on the proposed settlement. Respectfully submitted, For the Plaintiffs: For the Defendants: /s/ Sheila A. Bedi /s/ Michael T. Dierkes Roderick and Solange MacArthur Justice Center Michael T. Dierkes Northwestern University School of Law Assistant Attorney General 375 East Chicago Avenue General Law Bureau Chicago, Illinois 60611 100 W. Randolph, 13 th Floor (312) 503-1336 Chicago, Illinois 60601 (312) 814-3720 Dated: October 24, 2016 4
Case: 1:13-cv-07572 Document #: 122 Filed: 10/24/16 Page 5 of 5 PageID #:594 CERTIFICATE OF SERVICE The undersigned, an attorney, certifies that she served the foregoing document via the Court s CM/ECF system on October 24, 2016. /s/ Sheila A. Bedi 5
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Case: 1:13-cv-07572 Document #: 122-2 Filed: 10/24/16 Page 1 of 3 PageID #:614 NOTICE OF PAROLEE RIGHTS DURING THE PAROLE REVOCATION PROCESS YOU MAY REQUEST THAT THE DEPARTMENT OF CORRECTIONS REPRESENTATIVE READ THIS DOCUMENT TO YOU I. OVERVIEW OF THE PAROLE REVOCATION HEARING PROCESS You are being accused of violating the terms of your parole. Your parole violation report describes the violation(s) you are accused of committing. This document describes your rights during the parole revocation process. The revocation process is a two-step process. Before the Prisoner Review Board hears your case, you can have a preliminary revocation hearing during that hearing, a hearing officer listens to the evidence and decides whether there is probable cause to believe that you violated your parole. If probable cause is found, then you proceed to a final revocation hearing. During your final revocation hearing, the Prisoner Review Board will decide whether there is enough evidence to meet the preponderance standard. If the Prisoner Review Board believes there is enough evidence, it will find you in violation of your parole. If there is not enough evidence, depending on whether you have other charges pending against you, you may be released from custody. You have the right to be represented by an attorney throughout this process. You may be represented by an attorney or choose to represent yourself. You may hire private counsel of your choosing to represent you at your own expense. You may be eligible to have an attorney appointed to represent you at no cost to you if you cannot afford one. To be eligible, you must have a timely and colorable claim that you did not commit the alleged parole violation or, if you committed the violation, you must have substantial reasons why your parole should not be revoked (these reasons are called mitigation) that are complex or otherwise difficult to develop or present.. If you would like to be screened to determine whether you are eligible to have an attorney represent you, please complete the attached Preliminary Parole Revocation Hearing Form. What is probable cause? During your preliminary revocation hearing, the hearing officer will determine whether probable cause exists to believe that you violated your parole. Probable cause is whether a reasonable person would think there is enough evidence to believe you may have violated the terms of your parole. What does preponderance of the evidence mean? During your final parole revocation hearing, the Board will decide whether it is more likely than not that you violated parole. II. PAROLEE RIGHTS DURING SERVICE You will receive a copy of your alleged parole violation and this Notice of Rights. This process is called service.
Case: 1:13-cv-07572 Document #: 122-2 Filed: 10/24/16 Page 2 of 3 PageID #:615 During service, you must make some decisions about your preliminary parole revocation hearing. You are entitled to a preliminary parole revocation hearing to determine whether there is probable cause to believe that you violated your parole. You have the right to waive (or decide not to have) your preliminary revocation hearing. If you waive a preliminary revocation hearing, this does not mean that you have pled guilty to your parole violation. You will still have a final revocation hearing before the Prisoner Review Board. During service you have to make four decisions about the preliminary parole revocation process: 1) Would you like to go forward with a preliminary parole revocation hearing or would you like to waive your right to a hearing? 2) Would you like to be screened to determine if you are eligible for an appointed attorney? 3) Would you like to postpone your hearing? 4) Would you like to identify witnesses to testify on your own behalf during the preliminary parole revocation hearing? If you want to have witness testimony at your preliminary revocation hearing, you must include your witnesses names and contact information on the Preliminary Parole Revocation Hearing Form and you must return it to a representative of the Illinois Department of Corrections. You may also bring the form with you to your preliminary revocation hearing. Please complete the attached Preliminary Parole Revocation Hearing Form to indicate which decision(s) you have made. III. PAROLEE RIGHTS DURING THE PAROLE HEARINGS A hearing is a process during which the Prisoner Review Board or a hearing officer listens to the evidence and makes a decision. During a hearing you have the right to tell your side of the story. You have the right to show evidence during the hearing and to present witnesses. You have the right to attend your hearing and to ask questions of the people testifying against you. During the preliminary and final parole revocation hearing, you have the right to: Receive a screening to determine if you are eligible for an attorney, and if you are eligible, be appointed an attorney at no cost to you. Remain silent regarding any potential criminal charges. You do not have to admit to any wrongdoing and you have the right to refuse to answer any questions about your alleged violation, if it relates to potential criminal charges. Tell your side of the story, if you think it will help your case. Present witnesses. Ask questions of anyone who testifies at the hearing, unless the hearing officer specifically finds there is good cause for not allowing cross examination. Present documents related to the alleged parole violation. IV. PAROLE REVOCATION PROCESS TIMELINES There are timelines built into the parole revocation process, to make sure that you do not have to wait too long for a decision about your parole violation. Below is a summary of these timelines: 2
Case: 1:13-cv-07572 Document #: 122-2 Filed: 10/24/16 Page 3 of 3 PageID #:616 Within 5 days of your parole violation warrant being placed on record with the Illinois law enforcement entity that has physical custody of you(i.e., the Illinois Department of Corrections or the County Sheriff), you will receive a copy of your alleged parole violation and this Notice of Rights. This process is called service. If you are eligible for an appointed attorney, counsel will be appointed to you no less than two business days before your preliminary parole revocation hearing. If you are in custody in Cook County you will have your preliminary parole revocation hearing within 10 business days of service If you are in custody outside of Cook County and request to be screened for an attorney you will have your preliminary parole revocation hearing within 20 business days of service. If you are in custody outside of Cook County and do not request to be screened for an attorney you will have your preliminary parole revocation hearing within 10 business days of service. ***All Parolees have a right to request that their preliminary parole revocation hearing be postponed for up to 30 days*** If you did not have a preliminary parole revocation hearing or were not appointed counsel prior to your preliminary parole revocation hearing, you may request an attorney screening prior to your final parole revocation hearing. If you are found eligible, you will be appointed counsel no less than two business days before your final parole revocation hearing. Your final parole revocation hearing will occur within 90 days of service, unless you request a continuance, refuse to appear, are required by writ to appear in court or other legal proceedings, are unavailable due to medical or mental health reasons, are not at the Department of Corrections facility where the hearings are conducted, or because other extraordinary circumstances exist. 3
Case: 1:13-cv-07572 Document #: 122-3 Filed: 10/24/16 Page 1 of 1 PageID #:617 Preliminary Parole Revocation Hearing Admonishment You are here for a preliminary parole revocation hearing. During this hearing, I will determine whether probable cause exists to believe that you violated your parole. This means whether a reasonable person would think there is enough evidence against you to believe you may have committed the violation(s) described in the violation report. You have important rights during the hearing: You have the right to remain silent if you could be prosecuted for criminal charges in the parole violation report. You do not have to admit any wrongdoing and you may refuse to answer my questions, if the wrongdoing or questions relate to potential criminal charges. You have the right to provide witness contact information and to have me ask questions of your witnesses. If you provide me with the witness contact information for the first time today, I will make one attempt to call the witness or witnesses. If the witness or witnesses are unavailable today, you may ask to postpone this hearing to the next available preliminary hearing date, otherwise the hearing will go forward today. You have the right to present me with written documents. You have the right to tell me your side of the story -. You have the right to ask questions of anyone who testifies against you unless I specifically find good cause for not allowing cross examination. You have the right to be screened for an appointed attorney. If you meet the criteria, you will be appointed an attorney at no cost to you. You have the right to postpone this hearing. If you need additional time to exercise these rights, you may postpone your preliminary parole revocation hearing. I cannot force you to postpone the hearing. If I find that probable cause exists, you can ask that I recommend that the Prisoner Review Board release you pending your final hearing. You can present evidence and explain to me why I should make this recommendation. You will receive my decision in writing within one business day of the preliminary revocation hearing. Do you understand these rights? If you have not already been screened for an attorney, do you wish to be screened for one now? Do you wish to proceed with a preliminary parole revocation hearing?
Case: 1:13-cv-07572 Document #: 122-4 Filed: 10/24/16 Page 1 of 1 PageID #:618 Illinois Department of Corrections Preliminary Parole Revocation Hearing Form Parolee Name: Date of Birth IDOC Number: Date: Please answer each question below: 1) Would you like to proceed with a preliminary hearing? YES NO 2) Would you like to be screened to determine if you are eligible for an appointed attorney? YES NO 3) Would you like to postpone your hearing for up to 30 days? YES NO 4) Would you like to identify witnesses you would like to testify on your own behalf during the preliminary parole hearing? YES NO BELOW, PLEASE LIST ANY WITNESSES YOU WOULD LIKE TO TESTIFY AT YOUR PRELIMINARY PAROLE REVOCATION HEARING, AS WELL AS ANY POTENTIAL QUESTIONS OR TOPICS FOR THE WITNESS. YOU MUST INCLUDE A PHONE NUMBER IF YOU WOULD LIKE THE HEARING OFFICER TO CONTACT YOUR WITNESS. Witness Name & Phone Number Questions or Topics for Witness Parolee Signature: Date:
Case: 1:13-cv-07572 Document #: 122-5 Filed: 10/24/16 Page 1 of 1 PageID #:619 Final Parole Revocation Hearing Admonishment You are here for a final parole revocation hearing. After this hearing, the Prisoner Review Board will determine whether you committed a violation by a preponderance of the evidence. If the Prisoner Review Board believes there is enough evidence, it will find you in violation of your parole. If there is not enough evidence, depending on whether you have other charges pending against you, you may be released from custody. Even if to the Board finds that you violated your parole, you have the right to explain why the violation occurred and why your parole should not be revoked as a result of the violation. This is called mitigating evidence. You have important rights during the hearing: You have the right to remain silent if you could be prosecuted for criminal charges in the parole violation report. You do not have to admit any wrongdoing and you may refuse to answer questions, if the wrongdoing or questions relate to potential criminal charges. You have the right to provide witness testimony. You have the right to present written documents. You have the right to tell your side of the story. You have the right to ask questions of anyone who testifies against you unless there is a specific finding of good cause for not allowing cross examination. You have the right to be screened for an appointed attorney. If you meet the criteria, you will be appointed an attorney at no cost to you. You have the right to postpone this hearing. If you need additional time to exercise these rights, you may postpone your final parole revocation hearing. No one can force you to postpone the hearing. You will receive the Board s decision in writing as soon as possible. Do you understand these rights? If you have not already been screened for an attorney, do you wish to be screened for one now? Do you wish to proceed with a your final parole revocation hearing?
Case: 1:13-cv-07572 Document #: 122-6 Filed: 10/24/16 Page 1 of 4 PageID #:620 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION MOISES MORALES, et al., ) ) Plaintiffs, ) ) Case No.: 13-cv-07572 vs. ) ) Hon. Amy J. St. Eve ) CRAIG FINDLEY, et al., ) ) Defendants. ) PROPOSED NOTICE OF SETTLEMENT To: All people who, while on parole/mandatory supervised release, are supervised by the Illinois Department of Corrections The Illinois Department of Corrections ( IDOC ) and the Prisoner Review Board ( PRB ) have agreed to settle a class action lawsuit challenging the parole revocation process. The lawsuit was filed in October 2013 by the Roderick and Solange Macarthur Justice Center at the Northwestern University Pritzker School of Law and the Uptown People s Law Center ( Class counsel ) on behalf of all people who are supervised by the IDOC and who will be subject to parole proceedings conducted by the IDOC and the PRB. The lawsuit claimed that the parole revocation process was unfair and that it violated the due process rights of parolees because, in part, there was no process for screening and appointing counsel to those people who were entitled to the appointment of an attorney. The purpose of this Notice is to inform you of the status of the lawsuit, including your rights with respect to a Proposed Settlement of the case, and of the opportunity to file with the Court any objections you may have to the Proposed Settlement. The Settlement Class: The parties have agreed to a settlement class of all people who, while on parole/mandatory Supervised Release, are supervised by the IDOC and who now or in the future will be subject to parole revocation proceedings conducted by the IDOC and the PRB. If the Court approves this settlement and you are a member of the settlement class, this settlement will affect your rights. 1. Proposal to settle the case by adoption of a Settlement Agreement: The Plaintiffs and the Defendants have negotiated a document called a Settlement Agreement that would, if approved by the Court, settle this case. The Settlement Agreement would be monitored by an independent monitor and class counsel.
Case: 1:13-cv-07572 Document #: 122-6 Filed: 10/24/16 Page 2 of 4 PageID #:621 2. No money damages are involved in this case: The lawsuit does not involve money damages, so whether this case settles or goes to trial, no class member will obtain money from the Defendants. 3. Terms of the Proposed Settlement: The terms of the Proposed Settlement would require the parole process to function as described below: During the parole revocation process, parolees will have notice of the charges against them, an opportunity to explain their side of the story, and a hearing before a hearing officer or PRB member who will be fair and impartial. Parolees will also receive written findings at each stage of the parole revocation process. The revocation process will proceed as a two-step process. During the first stage, called the preliminary parole revocation hearing, a hearing officer would listen to the evidence and decide whether there is probable cause to believe that the violation may have occurred. If probable cause is found, then the parolee proceeds to a final revocation hearing before the PRB. During the final revocation hearing, the PRB will decide whether there is enough evidence to meet the preponderance standard. If there is not enough evidence, the parolee will be released, unless there are other pending charges or outstanding warrants. If a parolee cannot afford to hire an attorney and has a timely and colorable claim that he or she did not commit the alleged parole violation, the parolee has the right to be represented by an appointed attorney at no expense to him or her throughout the entire parole revocation process. If a parolee cannot afford to hire an attorney and the parolee committed the violation but has substantial reasons why his or her parole should not be revoked (these reasons are called mitigation ) that are complex or otherwise difficult to develop or present, the parolee has right to be represented by an appointed attorney at no expense to him or her during the final parole revocation hearing. The PRB will ensure that all parolees who request a screening will be screened to determine if they meet the criteria for an appointed attorney. Parolees also have the right to hire their own counsel at their own cost to represent them during the parole revocation process. There are also important deadlines in the parole revocation process, including the following: Within 5 days of the parole violation being placed on record with the Illinois law enforcement entity that has physical custody of the parolee (i.e., the Illinois Department of Corrections or the County Sheriff), the parolee will 2
Case: 1:13-cv-07572 Document #: 122-6 Filed: 10/24/16 Page 3 of 4 PageID #:622 receive a copy of the parole violation report and a Notice of Rights. This process is called service. If a parolee is screened and determined to be eligible for an appointed attorney, counsel will be appointed no less than two business days before the preliminary parole revocation hearing. Parolees in Cook County will have a preliminary parole revocation hearing within 10 business days of service (unless the parolee opts to waive or postpone the hearing). Parolees outside of Cook County who request to be screened for an attorney will have a preliminary parole revocation hearing within 20 business days of service (unless the parolee opts to waive or postpone the hearing). Parolees outside of Cook County who do not request to be screened for an attorney will have a preliminary parole revocation hearing within 10 business days of service (unless the parolee opts to waive or postpone the hearing). If a parolee did not have a preliminary parole revocation hearing or was not appointed counsel prior to the preliminary parole revocation hearing, the parolee may request an attorney screening prior to the final parole revocation hearing. If the parolee is found eligible, counsel will be appointed no less than two business days before the final parole revocation hearing. Final parole revocation hearings will occur within 90 days of service, subject to certain exceptions. The parties will agree to an independent monitor who will help the Defendants comply with this Settlement Agreement and who will report to the parties on the status of compliance. The Monitor will also meet with parolees and may look at their records to find out if the Defendants are following the agreement. Class counsel will also be involved in monitoring compliance with the Settlement Agreement. The summary of the Settlement Provisions in this Notice does not include all of the terms and conditions of the Proposed Settlement. The only complete statement of the terms of the Proposed Settlement is found in the actual Proposed Settlement Agreement. A copy of the Proposed Settlement attached to this Notice. You may also obtain a copy by writing to: Marissa Spalding, Paralegal Roderick and Solange MacArthur Justice Center Northwestern University School of Law 375 E. Chicago Avenue, Chicago, IL 60611 4. Reasons for Settlement: Class counsel have concluded that the terms and conditions of the Proposed Settlement are fair, reasonable, and adequate and are in the best interests of the class. In reaching this conclusion, Class counsel have carefully analyzed the benefits of settlement and the risks of an unfavorable outcome in this litigation, as well as the length of time that would be needed to prosecute this case through a trial and possible appeals. 3
Case: 1:13-cv-07572 Document #: 122-6 Filed: 10/24/16 Page 4 of 4 PageID #:623 5. If you do not object to the Proposed Settlement: If you do not object to the Proposed Settlement, you do not have to do anything, but you may write a letter of support in favor of the Proposed Settlement. 6. If you object to the Proposed Settlement: If you believe the Court should not approve the settlement of this case because you object to the terms of the Proposed Settlement, you may object. If you wish to object, you must object in writing. Objections must include the following information: The case name and number: Morales v. Findley (13-cv-07572); Your full name and contact information; and What it is exactly that you object to about the Proposed Settlement, with an explanation as to why you object. For your objection to be considered by the Judge, you must mail it in by to Class counsel: Marissa Spalding, Paralegal Roderick and Solange MacArthur Justice Center Northwestern University School of Law 375 E. Chicago Avenue, Chicago, IL 60611 Class counsel will collect the objections and give them to the Court prior to the fairness hearing mentioned below. 7. Fairness Hearing: The Court will hold a fairness hearing on, 2017 in the United States Federal Courthouse, 219 South Dearborn Street, Chicago, Illinois, to decide whether or not to approve the Proposed Settlement. If the Judge decides that the Proposed Settlement is fair, adequate, and a reasonable compromise of this case, then the Proposed Settlement will become final. 4