Jesus Sanchez V Wheeling Et Al

Case: 1:19-cv-02437 Document #: 1 Filed: 04/10/19 Page 1 of 37 PageID #:1
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
JESÚS SÁNCHEZ, )
) No:
Plaintiff, )
)
v. ) Judge
)
THE VILLAGE OF WHEELING, WHEELING )
POLICE DETECTIVE M. BIESCHKE, STAR NO. )
107, WHEELING POLICE SERGEANT VICTOR )
CHIRO, STAR NO. 75, WHEELING POLICE )
SERGEANT MICHAEL CONWAY, STAR NO. 74, )
WHEELING POLICE DETECTIVE J. CONNOLLY, )
STAR NO. 135, WHEELING POLICE DETECTIVE )
JOSEPH KOPECKY, STAR NO. 149, WHEELING )
POLICE DETECTIVE IGNACIO OROPEZA, )
STAR NO. 154, WHEELING POLICE DETECTIVE )
T. PINEDO, STAR NO. 120, THE CITY OF )
EVANSTON, EVANSTON POLICE DETECTIVE )
JOE BUSH, STAR NO. 246, EVANSTON POLICE )
DETECTIVE PHIL LEVY, STAR NO. 194, THE )
VILLAGE OF WILMETTE, WILMETTE POLICE ) JURY DEMAND
DETECTIVE LANDEN GIRARD, STAR NO. 564, )
THE VILLAGE OF LINCOLNWOOD, )
LINCOLNWOOD POLICE DETECTIVE )
SCHENITA STEWART, STAR NO. 128, THE )
VILLAGE OF SKOKIE, SKOKIE POLICE )
DETECTIVE RONALD GLAD, STAR NO. #203, )
)
Defendants. )
COMPLAINT
1. Plaintiff Jesús Sánchez, by and through his attorneys, files this complaint against
the individually named Defendants of the Wheeling Police Department (“WPD”), Evanston
Police Department (“EPD”), Wilmette Police Department (WiPD), Lincolnwood Police
Department (LPD) and Skokie Police Department (SPD) and their respective employing
municipalities, seeking compensation for the nearly five years he spent unjustly in prison and
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for the extreme emotional anguish and distress he suffered from his wrongful detention,
coercive interrogation, false charges, wrongful prosecution, and wrongful conviction and
incarceration for a crime - - the murder of Rafael Orozco - - that he did not commit. He also
seeks compensation for the physical pain, extreme emotional suffering and anguish he suffered
while incarcerated in jail and prison.
2. Jesús Sánchez was charged with killing Rafael Orozco after:
a. Defendants Bush, Oropeza and Connolly interrogated Jesús for close to 12

hours, physically and psychologically coercing him into making false
incriminating statements about the shooting death of Rafael Orozco, which
they fabricated by feeding him details of the crime and a false version of
the events; by repeatedly ignoring his assertions of innocence and the
forensic evidence of innocence; and repeatedly denying him access to his
mother and an attorney.
b. The Defendant Officers coerced Jesús’ alibi witnesses into making false
statements incriminating Jesús which the Defendant Officers fabricated,
coerced and forced the witnesses to recite during their oppressive and
lengthy interrogations.
3. Jesús was wrongfully convicted of the murder of Rafael Orozco on November 7,
2014 and he was sentenced to serve 45 years in prison on December 8, 2014.
4. On April 10, 2018, the Illinois Appellate Court reversed Jesús’ conviction,
finding that he was innocent of the murder of Rafael Orozco. The Illinois Appellate court ruled
that the central piece of incriminating evidence - - Jesús’ confession - - was involuntary and
unreliable, that the “police pressured the statement out of Sanchez,” and that the statement was
illegally obtained without informing him of his right to an attorney. The Court also found that:
the physical and eyewitness evidence “convincingly shows” that Jesús did not shoot and kill the
victim; that Jesús was wrongly arrested and detained on May 1, 2013 and subjected to over 12
hours of interrogation; and that in the course of his interrogation police detectives repeatedly
intimidated Jesús, lied to him about the evidence they falsely claimed incriminated him, forced
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him to make inculpatory and false statements, and denied him the right to speak with his
mother (in violation of 725 ILCS 5/103(a)), despite his repeated pleas to do so, and violated his
right to have his entire interrogation video recorded as required by Illinois state law (725 ILCS
5/103-2.1(b)).
JURISDICTION AND VENUE
5. The actions of the Defendants violated the United States Constitution, the Civil
Rights Act, 42 U.S.C. § 1983, as well as Illinois law. This Court has jurisdiction over Jesús’
federal claims pursuant to 28 U.S.C. §§ 1331 and 1343(a) and over his state law claims pursuant
to the court’s supplemental jurisdiction, as codified in 28 U.S.C. § 1367(a).
6. Venue is proper in this district under 28 U.S.C. § 1391(b). The parties reside, or,
at the time the events took place, resided in this judicial district, and the events giving rise to
Jesús’ claims also occurred in this judicial district.
PARTIES
7. Plaintiff Jesús Sánchez is a Latino man who was eighteen, living with his family
in Arlington Heights, Illinois and working two jobs at the time of his wrongful detention and
coercive interrogation.
8. Defendants Detective M. Bieschke, Sergeant Victor Chiro, Sergeant Michael
Conway, Detective J. Connolly, Detective Joseph Kopecky, Detective Ignacio Oropeza, and
Detective T. Pinedo were duly appointed and sworn WPD officers at all times relevant to this
Complaint.
9. Defendant Village of Wheeling is an Illinois municipal corporation. The Village
of Wheeling is or was the employer of Defendants Bieschke, Chiro, Conway, Connolly,
Kopecky, Oropeza, and Pinedo.
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10. Defendants Evanston Detectives Joe Bush and Phil Levy were duly appointed and
sworn EPD officers at all times relevant to this Complaint.
11. Defendant City of Evanston is an Illinois municipal corporation. The City of
Evanston is or was the employer of Defendants Bush and Levy.
12. Defendant Detective Landen Girard was a duly appointed and sworn WiPD
officer at all times relevant to this Complaint.
13. Defendant Village of Wilmette is an Illinois municipal corporation. The Village
of Wilmette is or was the employer of Defendant Girard.
14. Defendant Schenita Stewart was a duly appointed and sworn LPD officer at all
times relevant to this complaint.
15. Defendant Village of Lincolnwood is an Illinois municipal corporation. The
Village of Lincolnwood is or was the employer of Defendant Stewart.
16. Defendant Ronald Glad was a duly appointed and sworn SPD officer at all times
relevant to this complaint.
17. Defendant Village of Skokie is an Illinois municipal corporation. The Village of
Skokie is or was the employer of Defendant Glad.
18. At all times relevant to this action, each of the named individual Defendants acted
in the scope of his or her employment, and under color of the laws, regulations, and customs of
the State of Illinois. Each individual Defendant is sued in his or her individual capacity. The
actions of each Defendant, both individual and governmental, constituted “state action” as
defined under federal law.
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FACTUAL ALLEGATIONS
A. The Shooting of Rafael Orozco
19. Rafael Orozco was tragically shot in the back and killed while standing in a
courtyard in the Pleasant Run apartment complex (“Pleasant Run courtyard”) in Wheeling,
Illinois on May 1, 2013 at approximately 9:00 p.m.
20. Mr. Orozco was standing among a group of men and boys at the south end of the
courtyard under a streetlight when gunshots were fired.
21. Defendants Conway, Bieschke, Pinedo, Chirio, Oropeza, and several other law
enforcement officers from Wheeling and other suburban police departments and paramedics
responded to the scene.
B. Plaintiff Jesús Sánchez’s Location and Alibi Witnesses
22. At the time Mr. Orozco was shot, Jesús was with Bryan Estrada, Heladio
Flores, Collin Scheffler, Leslie Rubio, and Bradley Chambre on Bridle Trail Lane, in the
Longacre subdivision, south of the Pleasant Run courtyard.
23. Jesús and the persons he was with had nothing to do with the shooting of Mr.
Orozco.
24. Several minutes after the shooting, Leslie walked to the site of the shooting
where she learned that Mr. Orozco was shot and she shared this information with Jesús and
the others.
25. Jesús, Bryan and Heladio then attempted to get to Jesús’ car which he had
parked on the west side of the Pleasant Run apartment complex several hours earlier that day.
C. Jesús Sanchez’s Unlawful Detention
26. As they were attempting to get to Jesús’ car, Jesús, Bryan and Heladio were
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spotted by members of the Sureños 13 gang, who chased them in the Pleasant Run apartment
complex.
27. As Jesús and Bryan were running away from the Sureños 13 gang members,
Defendants Conway and Chirio unlawfully detained them without probable cause or
reasonable suspicion.
28. Both Jesús and Bryan were handcuffed and transported to the WPD.
29. Jesús was wearing a black tank top and plaid shorts throughout the afternoon and
evening of May 1, the same clothes he was wearing when he was arrested and brought to the
WPD.
30. At the WPD, Jesús and Bryan were put into two separate interrogation rooms
at approximately 10:20 p.m.
31. Jesús was detained in this 10-by-10 foot windowless interrogation room
throughout the remainder of May 1 through May 2, 2013.
32. Heladio was also stopped by officers late in the evening on May 1, 2013 and
was transported to the WPD.
D. Jesús Sánchez’s Interrogation on May 1, 2013
33. Defendants Oropeza and Connolly interrogated Jesús about the shooting of Mr.
Orozco on May 1, 2013 from 10:20 p.m. to 11:40 p.m.
34. Defendants Oropeza and Connolly did not give Jesús Miranda warnings prior
to this interrogation.
35. Defendants Oropeza and Connolly were aware that Jesús was 18 years old, he
had no criminal record, English was not his first language, and he had not graduated from
high school.
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36. Defendants Oropeza and Connolly questioned Jesús about his activities and
whereabouts on May 1 and Jesús truthfully informed these Defendants that he was near the
pond south of Bridle Trail Lane in the Longacre subdivision when he heard the gunshots and
that he then attempted to discover whether his friend Miguel was shot.
37. This interrogation was not video recorded, in violation of Illinois law.
E. Heladio Flores’ Interrogation on May 1, 2013
38. Defendants Bieschke and Detective McGuire interrogated Heladio from
approximately 10:40 to 11:56 p.m. on May 1.
39. Defendants Bieschke and Detective McGuire were aware that Heladio was 15
years old but they interrogated him without the presence of his parents.
40. During this initial interrogation, Heladio truthfully informed Defendant
Bieschke and Detective McGuire that he was with Jesús and Bryan at the pond off Bridle
Trail Lane in the Longacre subdivision when he heard the gun shots.
F. The NORTAF Investigation of Rafael Orozco’s Murder
42. Within an hour of the shooting, members of the North Regional Major Crimes
Task Force (NORTAF), comprised of several different officers from North Shore suburban
police departments, cordoned off the courtyard where Mr. Orozco was shot and began
conducting interviews of eyewitnesses and investigating the area for physical and forensic
evidence.
43. NORTAF and Defendant Officers quickly determined from the forensic evidence,
including a bullet jacket, footwear impressions and eyewitness evidence, that the gunshots were
fired from the area near Equestrian Drive, a street south of where Mr. Orozco was standing at the
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time he was shot.
44. At approximately 11:45 p.m. on May 1, Defendants Bush and Pinedo interviewed
Uriel Edgar Martinez, who was standing in the same courtyard where Mr. Orozco was shot.
45. Martinez informed Defendants Bush and Pinedo that he observed a white SUV
driving very slowly with its headlights off heading westbound on Equestrian Drive, that he saw a
man wearing a light blue shirt and white shorts exit the rear passenger side door of the white
SUV while the vehicle was moving slowly and walk westbound with the white SUV travelling
alongside him, and that approximately one minute after he saw this unidentified man exit the
vehicle he heard gunshots. He did not see the man or white SUV after he heard the gunshots.
46. At approximately 11:30 p.m., WPD Officer J. Hoffman spoke with Volodymyr
Motkalyuk, who informed Officer Hoffman that after he heard gunshots, he saw a black or
dark colored sedan travelling at a high rate of speed westbound on Equestrian Drive from the
Pleasant Run apartment complex with its headlights off, and that after it passed Equestrian
Park (located west of the Pleasant Run courtyard) the vehicle lights were illuminated.
G. Jesús Sánchez’s Interrogation on May 2, 2013 at 2:50 a.m.
47. On May 2, 2013, from 2:50 to 3:20 a.m., Defendants Oropeza and Connolly
interrogated Jesús a second time, again without advising him of his Miranda rights.
48. This second interrogation was also not video recorded, in violation of Illinois
law. Jesús again truthfully told Defendants Oropeza and Connolly that he was at Bridle Trail
Lane when heard the gunshots.
H. Heladio Flores’ Interrogation on May 2, 2013 at 3:36 a.m.
49. On May 2, 2013, from approximately 3:36 to 5:04 a.m., Defendants Bieschke
and Kopecky questioned Heladio a second time.
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50. Heladio informed Defendants Bieschke and Kopecky that he was with Jesús
and Bryan when his friend Collin drove up and parked in the parking lot on Bridle Trial Lane
and after he heard the gunshots, he and the others got in Collin’s car and travelled to the
Pleasant Run apartment complex.
51. This second interrogation was also not video recorded in violation of Illinois
law.
I. Bryan Estrada’s Interrogations on May 1 and 2, 2013
52. Defendants Bieschke and Pinedo questioned Bryan on May 1, 2013 from
approximately 11 to 11:30 p.m., and Defendants Bieschke and Kopecky questioned Bryan a
second time on May 2 from approximately 6 to 7:20 a.m.
53. Defendants Bieschke, Pinedo and Kopecky were aware that Bryan was 14
years old but they interrogated him without his parents.
55. Bryan informed Defendants Bieschke and Kopecky that he was with Jesús,
Heladio, Collin and Leslie at the Bridle Trail pond in the Longacre subdivision when the
shots were fired.
J. The Conspiracy to Frame Jesús Sanchez for the Murder of Rafael Orozco
56. In the morning hours of May 2, the Defendant Officers conspired and agreed
amongst themselves that they were going to charge either Jesús and/or Bryan with the
murder of Rafael Orozco.
57. In furtherance of this conspiracy, the Defendants determined that they were
going to coerce Jesús into giving a false statement that he shot and killed Rafael Orozco,
either accidentally and/or in self-defense, and that they were going to coerce Bryan and
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Heladio, and if necessary other witnesses, to falsely state the same or, in the alternative,
have them provide false corroborating incriminating statements that they observed Jesús
and/or Bryan with a gun and that Jesús and/or Bryan were in the area where the shooting
occurred.
58. When the Defendant Officers embarked on this conspiracy, they knew that
Jesús’ clothing did not match the clothing description of the suspected shooter observed by
eyewitness Martinez.
59. The Defendant Officers also knew that Jesús was not observed in or around,
and he did not possess or drive, the make and model of the cars - - a white SUV or a black or
dark colored sedan - - suspected of being involved in the shooting.
60. The Defendant Officers also knew that no eyewitness at that time claimed that
they saw Jesús commit the shooting or that Jesús had a gun.
61. In furtherance of their conspiracy to coerce Jesús and others into giving false
incriminating statements, the Defendant Officers agreed to administer presumptive gunshot
residue (PGSR) tests to Jesús, Bryan and Heladio.
62. The Defendant Officers knew or should have known that this test was not
accurate, reliable and/or that it was likely to produce flawed results regarding the detection
and presence of gunshot residue on an individual, and that it did not provide any certainty as
to whether an individual shot or held a gun.
63. In furtherance of the conspiracy, WPD Detective Conboy conducted a PGSR
test on Jesús’, Bryan’s and Heladio’s hands in the early morning hours of May 2, 2013.
64. According to Conboy and the other Defendant Officers, Jesús’ hands tested
positive for the presence of gunshot residue from the PGSR test.
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65. The Defendant Officers then deliberately used this alleged positive finding
from the PGSR throughout their interrogations of Jesús and his alibi witnesses to convince
them to make false incriminating statements about Jesús’ responsibility for the murder of
Mr. Orozco.
66. The Defendant Officers began to video record Jesús in his interrogation room
at 6:44 a.m. on May 2, 2013.
67. At the time video recorder was turned on Jesús was lying on the floor beneath
the table in the interrogation room.
K. Jesús Sanchez’s Interrogation on May 2 at 7:50 a.m.
68. Defendants Bush and Oropeza entered the interrogation room and interrogated
Jesús from 7:54 to 9:17 a.m.
69. Prior to the questioning, Defendants Bush and Oropeza provided Jesús his
Miranda rights in writing and asked him to read them, but they never had him sign the form
indicating he was waiving his Miranda rights.
70. During this interrogation, Jesús initially gave an honest account of his activities
on May 1, in which he denied any involvement in the murder of Mr. Orozco.
71. Defendants Bush and Oropeza refused to accept Jesús’ truthful recitation of his
whereabouts at the time the gunshots were fired, his denial that he had a gun, and that he did not
shoot anyone.
72. Instead, using psychological and physical coercion, repeatedly lying about the
witnesses’ statements and denying Jesús his right to leave the police station, his right to end the
interrogation, and his right to see and speak with his mother, Defendants Bush and Oropeza
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forced Jesús to give inculpatory statements which they fabricated, in which he acknowledged
that he shot and killed Mr. Orozco.
73. After the Defendant Officers left the room, Jesús crawled down on the floor and
laid a chair on its side to use as a head rest.
L. Jesús Sanchez’s Interrogation on May 2 at 9:52 a.m.
74. The Defendant Officers were aware that the statements they had coerced Jesús
into giving were false and inconsistent with the physical evidence and statements from
eyewitnesses.
75. Defendants Bush and Oropeza then re-interrogated Jesús in attempt to coerce him
to change his statement to make it more consistent with the other evidence.
76. During this re-interrogation, Defendants again used psychological and physical
coercion, and denied Jesús his right to leave the police station, his right to end the interrogation,
his right to see and speak with his mother, and his right to a lawyer.
77. During this re-interrogation, Jesús again made statements to these Defendants
that showed that he did not have knowledge of the murder and that his statements were
inconsistent with his guilt.
M. Heladio Flores’ Interrogation on May 2 at 10:14 a.m.
78. After Heladio had spent the night at the WPD, Defendants Bieschke and
another detective transported him to the Glenview Police Department on May 2 at 9:51 a.m.
79. Defendant Bieschke interrogated Heladio for several hours, refusing to accept
his account in which he truthfully related that neither he nor Jesús or Brian had any
involvement in the murder, and suggesting several stories which inculpated him, Jesús and
Brian.
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80. Eventually, as a result of the coercion, repeated lies about the evidence,
fabrication and suggestions of Defendant Bieschke, Heladio made statements that were
inculpatory of Jesús, but which were inconsistent with the physical evidence and witness
accounts.
81. Defendant Bieschke knew that the statements he had coerced and fabricated
from Heladio were false.
N. Heladio’s Interrogation on May 3
82. On May 3, 2013, Defendants Bieschke and Bush interrogated Heladio again.
83. These defendants, using coercion, fabrication and suggestions, caused Heladio
to make statements during this interrogation that were inculpatory of Jesús, but which were
inconsistent with the physical evidence and witness accounts.
O. The Arrests and Interrogations of Alibi Witnesses Collin Scheffler, Leslie

Rubio, and Bradley DeChambre
84. Without any credible physical evidence linking Jesús to the crime, and with
coerced, fabricated, false and unreliable statements from Jesús regarding how the shooting
occurred that were contradicted by the physical and eyewitness evidence, the Defendant
Officers determined that they needed additional witness testimony to falsely charge and convict
Jesús for the murder of Mr. Orozco.
85. In furtherance of this conspiracy, the Defendants Officers agreed to falsely arrest
Collin Scheffler, aged 19, Leslie Rubio, aged 18, and interview Bradley DeChambre, aged 26,
in an attempt to coerce fabricated statements from them wherein they would provide false
incriminating information implicating Jesús in Mr. Orozco’s murder.
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1. Collin Scheffler’s Arrest and Two-Day Interrogation
86. Defendants Levy and Stewart arrested Collin Scheffler at his home on May 2,
2013, at about 11:15 a.m.
87. There was no probable cause to arrest or detain Collin, but Defendants Levy and
Stewart wrote a false police report which represented that there was.
88. Collin was taken to the WiPD where he was interrogated for close to six hours on
May 2 by Defendants Steward and Girard.
89. Collin consistently told the truth about his whereabouts on May 1 at the time of
the shooting, but Defendants Girard and Stewart repeatedly called him a liar, lied to and misled
him about the evidence, threatened him and fed him facts until he cried and broke down, and he
eventually regurgitated the Defendant Officers’ fabricated, false narrative the following day.
90. During the interrogation Collin repeatedly told Defendants Girard and Stewart
that he wanted to go home and go to sleep, which he was entitled to do since there was no true
probable cause supporting his detention, and he begged them to allow him to leave but they
refused to do so.
91. The Defendant Officers and other law enforcement officials prevented Collin’s
family members from speaking with him despite their repeated requests to do so.
92. After Defendants Stewart and Girard ended their questioning of Collin on May 2
and before they resumed their questioning of him on May 3, they spoke with and conspired with
the other Defendant Officers.
93. The Defendant Officers agreed that Defendants Stewart and Girard would coerce
Collin to give false incriminating statements wherein Collin would say that Jesús exited Collin’s
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car on Equestrian Drive, near the location where the shots were fired from, with a gun, shortly
before the shots were fired on May 1, 2013.
94. On May 3, 2013 at approximately 1:50 p.m., Defendants Stewart and Girard
resumed their questioning of Collin and the questioning continued for close to three hours.
95. During this interrogation session, Collin repeatedly tried to tell the truth, but
Defendants Stewart and Girard refused to listen to him and continually lied to him and misled
him about the evidence and fed him a false narrative which they repeatedly pushed him to
regurgitate.
96. Eventually, after several hours of interrogation, after being refused access to his
family and the ability to leave the police station, Collin, who was visibly exhausted, isolated,
frustrated, and emotionally overwrought, broke down, cried, and began to incorporate the
version of events fed to him by Defendants Girard and Stewart.
97. As a result of the coercion and fabrication by Defendants Stewart and Girard and
the other misconduct set forth herein, Collin gave an account of the murder that was inculpatory
of Jesús.
98. Throughout the two days of interrogation, Defendants Girard and Stewart
repeatedly ignored or refused Collins’ requests to go home and to speak with his parents.
99. During the course of the interrogation, Defendants Girard and Stewart fed false
facts for Collin to regurgitate and lied about the existence of evidence including, but not limited
to: the existence of gunshot residue being found in Collin’s car, tire marks matching the rubber
on the tires of his car, and the existence of surveillance video of him or his car.
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2. Leslie Rubio’s Arrest and Two-Day Interrogation
100. In furtherance of this conspiracy, Defendants Girard and Glad and another officer
arrested Leslie in Wheeling on May 2, and Defendant Glad and the other officer transported her
to the SPD.
101. There was no true probable cause for the arrest and detention of Leslie.
102. Between approximately 12:30 and 4:30 p.m., Defendants Glad and Levy
interrogated Leslie about events that occurred on May 1.
103. During Leslie’s interrogation, she informed Defendants Glad and Levy that she
was with Jesús and others on Bridle Trail Lane in the Longacre subdivision at the time they
heard the gunfire.
104. Leslie told these Defendants that after the shooting they saw a dark colored car,
like a sedan, driving west on Equestrian Drive, corroborating the information Volodymyr
Motaklyuk told Officer Hoffman the night of the shooting.
105. Defendants Glad and Levy refused to accept Leslie’s account and instead
threatened her in an effort to get her to change her account, telling her that if she did not provide
an account that implicated Jesús she would be charged with the murder and she would be locked
up.
106. While detained in the interrogation room, Leslie requested that she be allowed to
call a lawyer, but she was not permitted to do so.
107. Throughout her detention at the SPD, when left alone in the interrogation room
Leslie was handcuffed to the wall.
108. At approximately 6 p.m. Leslie was transported to the WPD and detained
overnight.
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109. The following day, on May 3, 2013, Leslie was interrogated again by Defendants
Pinedo and Levy who coerced her to waive her Miranda rights.
110. Leslie requested that she be allowed to leave the police station, but Defendants
Levy and Pinedo did not allow her to do so.
111. Leslie attempted to truthfully describe that she was with Jesús on May 1 and he
was not involved with the murder of Mr. Orozco, but Defendants Levy and Pinedo threatened
her, lied to her about what other witnesses had related, and continually suggested fabricated
accounts of the murder in which Jesús was implicated.
112. Eventually, after several hours of interrogation, Defendants Pinedo and Levy,
through coercion, threats, fabrication and misrepresentation, forced Leslie to change her account
and give a version that had been fabricated by the Defendant Officers in which Jesús was
implicated in the murder.
113. Defendant Levy created a police report in which he misrepresented Leslie’s
statement, deliberately omitting that Leslie adamantly denied that Jesús had a gun, after they
pushed her into saying he did, and that she told them they were framing Jesús for a crime he did
not commit.
114. Leslie was released from WPD on May 4, 2013 at approximately 3 p.m.
3. The Interrogation of Bradley DeChambre
115. Bradley DeChambre was initially interrogated by Defendant Chirio and Evanston
Detective Tom Hanus at the WPD beginning at approximately 2:30 p.m. on May 2, 2013.
116. During this interrogation, Bradley truthfully told Defendant Chirio and Detective
Hanus that he and the others, including Jesús, were at Bridle Trail Lane in the Longacre
subdivision at the time they heard gunshots.
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117. Bradley was subsequently interrogated by Defendant Bush and he also told him
that he was with Jesús when they heard gunshots and that Jesús was not involved in the
shooting.
118. Defendant Bush attempted to get Bradley to change his account and implicate
Jesús and Bryan, but his attempts were thwarted when Bradley’s father arrived at the police
station and demanded that the interrogation end.
P. Additional Forensic Evidence
119. Further forensic investigation revealed that the shot that killed Mr. Orozco came
from the south to the north, there was no gun found in either Collin’s or Jesús’ cars, and no gun
was ever recovered.
Q. The Charges Lodged Against Jesús Sanchez and Collin Scheffler
120. On May 4, 2013, Defendant Kopecky completed the sworn criminal complaints
charging Jesús and Collin with First Degree Murder of Rafael Orozco and the attempted murder
of Edson Calleros.
121. Cook County Assistant State’s Attorney David Weiner approved the felony
charges against Jesús based on the coerced and fabricated statements taken by the Defendant
Officers of Jesús and his alibi witnesses, including Collin’s incriminating statements.
122. On or about May 6, 2013, Jesús and Collin had a bond hearing in the Circuit
Court of Cook County.
123. A Circuit Court County Judge set Jesús’ bond at $2 million and Collin’s bond at
$500,000.
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124. Jesús was unable to pay the bond and he remained in custody throughout his
criminal proceedings, trial, sentencing and imprisonment, thereby continuing the wrongful
detention that began on May 1, 2013.
R. The Exonerating Physical and Forensic Evidence
125. There was and is no physical evidence linking Jesús to this crime.
126. All of the standard gunshot residue detection tests that were conducted by the
Illinois State Police failed to detect any residue on Jesús’, Bryan’ or Heladio’s hands or clothes
or in Collin’s car.
127. After extensive interviews with numerous witnesses, none indicated that Jesús
fired a gun, and the only evidence that Jesús possessed a gun came from the false and fabricated
statements elicited from Jesús, Heladio and Collin.
S. Collin Scheffler’s Malicious Prosecution
128. Collin was falsely charged with six counts of First Degree Murder of Rafael
Orozco, one count of attempted first degree murder of Edson Calleros, and one count of
aggravated discharge of a firearm.
129. On September 10, 2014, Collin was acquitted of all criminal charges after a
bench trial.
130. After his acquittal, Collin proclaimed his innocence and announced that he
refused to take a plea deal.
131. Thereafter, Collin attended Jesús’ trial proceedings and was quoted as saying “I
know he didn’t do this shooting, that’s why I’m showing up.”
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T. Jesús Sánchez’s Wrongful Conviction
132. Jesús was falsely charged with twelve counts of First Degree Murder of
Rafael Orozco, three counts of Attempted First Degree Murder of Edson Calleros and one
count of Aggravated Discharge of a Firearm, based on the coerced and fabricated statements
the Defendant Officers elicited from him and his alibi witnesses.
133. Jesús filed a motion to quash arrest and suppress his statements and a motion
to suppress his statements, contending he was arrested without probable cause prior to his
interrogation at the WPD and that the statements were involuntary, the production of
physical and mental coercion, and taken in violation of his rights guaranteed by Miranda
and Illinois state law.
134. Both motions were denied after Defendants Officers lied and said they did not
arrest Jesús at the scene, did not coerce him and provided him with the required Miranda
warnings.
135. After Jesús’ motions to suppress his statements were denied, parts of Jesús’
videotaped interrogation, including the false, fabricated incriminating statements he was coerced
into making, were admitted as evidence against him at his trial.
136. The Cook County State’s Attorney’s Office also called Heladio to testify and
admitted parts of his videotaped interrogation wherein he made incriminating statements about
Jesús and the shooting.
137. At trial, Heladio recanted his statements wherein he said he observed Jesús with
a gun, stating that they were lies, and testified that the police convinced him that Jesús had
already confessed, that he acquiesced in the police version of events to avoid being charged
himself, and that the Defendant Officers fed him false and fabricated information which he
regurgitated to them.
20
138. Heladio testified to the account he had initially told police: that he, Jesús, and
four other youths were standing at Bridle Trail Lane when they heard the gunshots.
139. Heladio also described that, similar to Jesús, he was interrogated in a room
without a parent and without the interrogation being recorded initially.
140. In closing arguments, an Assistant Cook County State’s Attorney repeatedly
cited to Jesús’ confession and admissions, arguing they proved he was guilty.
141. Jesús was convicted by a jury of the murder of Rafael Orozco with a firearm, and
he was acquitted of the attempted murder of Edson Calleros, on November 7, 2014.
142. Jesús was sentenced on December 8, 2014 to serve 45 years in prison.
U. Jesús Sánchez’s Exoneration on the Basis of His Innocence
143. The coercion and fabrication of false inculpatory evidence from Jesús and his
alibi witnesses described above materially and significantly continued the wrongful detention
and prosecution of Jesús, substantially delayed Jesús’ exoneration, and caused Jesús to face
many additional years of unjust incarceration that he would not have endured if this coercion
and fabrication had not occurred.
144. On April 10, 2018, the Illinois Appellate Court reversed Jesús’ conviction,
finding that he was innocent of the murder of Rafael Orozco. The court ruled that the central
piece of incriminating evidence - - Jesús’ confession - - was unreliable and involuntary.
145. The Illinois Appellate Court also found that the physical and eyewitness evidence
“convincingly shows” Jesús did not shoot and kill the victim.
146. The Illinois Appellate Court further found that Jesús was falsely arrested on May
1, 2013 and subjected to over 12 hours of interrogation, and that in the course of that
interrogation Defendant Officers pressured Jesús to make an incriminating statement, repeatedly
intimidated him, lied to him about the evidence they falsely claimed incriminated him, prodded
21
him into making false statements, and denied him the right to speak with his mother, despite his
repeated pleas to do so.
147. The Illinois Appellate Court also found that the Defendant Officers failed to give
Jesús his constitutionally required Miranda rights, violated his right to speak with a parent
guaranteed by Illinois law (in violation of 725 ILCS 5/103(a)), and violated his right to have his
entire interrogation video recorded as required by Illinois state law (725 ILCS 5/103-2.1(b)).
148. In reversing Jesús’ conviction, the Appellate Court found Jesús’ case was an
illustrative example of “how the use of deceptive practices in interrogations leads to false
confessions.”
149. The Illinois Appellate Court recommended the WPD consider sanctioning the
WPD Defendant Officers and others for refusing to allow Jesús to call his mother.
150. Jesús was released from the Illinois Department of Corrections on April 17,
2018.
151. As a result of the actions of the individual Defendants, Jesús was wrongfully
detained and imprisoned, suffering the most extreme curtailments of his liberty, for close to five
years.
152. On November 6, 2018, the Circuit Court of Cook County found, pursuant to 735
ILCS 5/2-702, that Jesús was innocent of the charges for which he was convicted and granted
him a Certificate of Innocence.
V. The Defendants’ Misconduct Was Committed in Furtherance of a

Conspiracy.
153. All of the named individual Defendants, acting jointly and with other police and
prosecutorial investigative, supervisory, and command personnel, together reached an
understanding, engaged in an ongoing course of conduct and joint action and otherwise
conspired and continue to conspire among and between themselves to deprive Jesús Sanchez of
22
his constitutional rights and rights guaranteed by Illinois state law. By the overt acts set forth
above, these Defendant officers deprived and continue to deprive Jesús of those rights, including
his right to be free from unreasonable seizure and wrongful confinement and imprisonment; his
right to be free from involuntary self-incrimination and from false and fabricated evidence being
used to detain, charge, and used and against him in his criminal proceedings and at trial; his
right to access to the courts and to a fair and impartial trial; all as protected by the Fourth, Fifth,
and Fourteenth Amendments to the United States Constitution.
W. Jesús Sánchez’s Damages
154. Jesús was subjected to the extreme curtailment of his liberty while in prison. In
addition to being physically injurious, this time was emotionally and psychologically grueling,
and Jesús suffered from constant fear and anxiety, deep depression, despair, rage, isolation,
boredom and loneliness causing him to attempt to kill himself while incarcerated.
155. Jesús continues to experience pain and suffering, humiliation, constant fear,
anxiety, deep depression, despair, rage, and symptoms of post-traumatic stress disorder from his
wrongful detention, coercive interrogation, malicious prosecution, wrongful conviction and
wrongful incarceration.
COUNT I
42 U.S.C. § 1983 Claim for the Deprivation of the
Right to a Fair Trial and for Wrongful Conviction
156. Jesús re-alleges all of the preceding paragraphs and incorporates them in this
count.
157. Defendants Bieschke, Chiro, Conway, Connolly, Kopecky, Oropeza, Pinedo,
Bush, Levy, Girard, Stewart and Glad, individually, jointly, and in conspiracy, caused the
wrongful charging, prolonged detention, prosecution, conviction, and imprisonment of Jesús.
23
158. These Defendants caused and/or continued Jesús’ wrongful detention, charging,
prosecution, conviction and imprisonment by committing or causing to be committed one or
more of the following acts: constructing and/or fabricating Jesús’ false and unreliable
confession and the incriminating statements of Heladio, Collin, and Leslie which formed the
basis for Plaintiff’s charging, unlawful detention, prosecution and conviction; withholding from
the prosecutors, judges and defense attorneys involved in Jesús’ prosecution the facts of the
unrecorded interrogations of Jesús and other witnesses; and by the additional wrongdoing that is
set forth above in this Complaint.
159. In engaging in the conduct described in this Complaint, the individually named
Defendants unconstitutionally deprived Jesús of his liberty and violated his right to a fair and
impartial trial and not to be wrongfully convicted, as guaranteed by the Fourth and/or
Fourteenth Amendments to the U.S. Constitution.
160. Additionally and/or alternatively, the individual Defendants failed to intervene to
stop Jesús’ wrongful detention, coercive interrogation, wrongful prosecution, conviction, and
imprisonment despite having the opportunity and duty to do so.
161. The actions of the individual Defendants as set forth in this Complaint were a
direct and proximate cause of the injuries to Jesús set forth above.
WHEREFORE, Jesús demands judgment against Defendants Bieschke, Chiro, Conway,
Connolly, Kopecky, Oropeza, Pinedo, Bush, Levy, Girard, Stewart and Glad for compensatory
damages, and, because these Defendants acted maliciously, willfully, wantonly, and/or with
reckless disregard for Jesús’ constitutional rights, for punitive damages, plus the costs of this
action, attorneys’ fees and such other relief as this Court deems equitable and just.
24
COUNT II
42 U.S.C. § 1983 Claim for Coercive Interrogation
162. Plaintiff re-alleges all of the preceding paragraphs and incorporates them in this
count.
163. The actions of Defendants Bush, Connolly and Oropeza, individually, jointly,
and in conspiracy, in denying Jesús his Miranda rights and coercively interrogating Jesús and
causing him to make false and fabricated admissions, violated Jesús’ Fifth and Fourteenth
Amendment rights to be free from compulsory self-incrimination and deprivation of liberty
without due process of law.
164. These false and fabricated admissions were introduced against Jesús at his
criminal trial.
165. Additionally and/or alternatively, Defendants Bieschke, Chiro, Conway,
Connolly, Pinedo, Levy, Girard, Stewart and Glad failed to intervene to stop Jesús’ coercive
interrogation, and the resulting wrongful prosecution, conviction and imprisonment, despite
having the opportunity and duty to do so.
166. The actions of Defendants Bush, Connolly and Oropeza in using coercive
techniques to interrogate Jesús, and/or, together with Defendants Bieschke, Chiro, Conway,
Kopecky, Pinedo, Bush, Levy, Girard, Stewart and Glad, in condoning and permitting the use of
said techniques, were the direct and proximate cause of Jesús’ injuries and damages as more
fully set forth above.
Connolly, Kopecky, Oropeza, Pinedo, Bush, Levy, Girard, Stewart and Glad, for compensatory
25
COUNT III
42 U.S.C. § 1983 Fourth Amendment Claim for Wrongful Detention
count.
Bush, Levy, Girard, Stewart and Glad caused Jesús to be unreasonably seized, detained,
imprisoned and deprived of his liberty without probable cause to believe that he had committed
a crime, in violation of his rights secured by the Fourth Amendment to the United States
Constitution.
169. As a result of this misconduct, Jesús lost his freedom and sustained, and
continues to sustain, injuries, including physical injury and sickness and emotional pain and
suffering.
COUNT IV
42 U.S.C. § 1983 Fourth and Fourteenth Amendment
Claim for Failure to Intervene
count.
26
Bush, Levy, Girard, Stewart and Glad were aware of the constitutional violations as set forth
above and had the opportunity and duty to intervene and prevent the violation of Jesús’
constitutional rights, but they failed to do so.
172. The misconduct described in this Count was objectively unreasonable and was
undertaken intentionally, with malice and willful indifference to Jesús’ clearly established
constitutional rights.
173. As a direct and proximate result of these Defendants’ failure to intervene to
prevent the violation of Jesús’ constitutional rights, Jesús suffered injuries as set forth above,
including but not limited to loss of liberty, physical harm, and emotional distress.
COUNT V
42 USC §1983 Claim for Conspiracy
count.
175. The actions of Defendants Bieschke, Chiro, Conway, Connolly, Kopecky,
Oropeza, Pinedo, Bush, Levy, Girard, Stewart and Glad as set forth above constituted a
conspiracy and/or joint action under the Fourth and Fourteenth Amendments to falsely charge
and convict Jesús, to cover up their violations, and to protect themselves from being disciplined
and fired for their actions, as well as to prevent Jesús from availing himself of his constitutional
27
rights and protections.
176. The actions of Defendants Bieschke, Chiro, Conway, Connolly, Kopecky,
Oropeza, Pinedo, Bush, Levy, Girard, Stewart and Glad in conspiring to deprive Jesús of his
rights was the direct and proximate cause of the violations of Jesús’ rights as set forth above.
COUNT VI
§ 1983 Claim for Malicious Prosecution1
count.
178. The Defendant Officers, despite knowing that probable cause did not exist to
arrest and prosecute Jesús, acted individually and in concert to cause Jesús to be arrested and
prosecuted, thereby violating Jesús’ rights pursuant to the Fourth and/or Fourteenth Amendments
of the United States Constitution to be free of unreasonable searches and seizures and to due
process.
179. Despite the fact that the Defendant Officers were aware of information that
probable cause did not exist to detain Jesús, the Defendant Officers intentionally caused him to
1
Plaintiff recognizes that the Seventh Circuit Court of Appeals has held that there is no cause of
action for malicious prosecution under 42 U.S.C. § 1983, under either a Fourth or a Fourteenth
amendment theory. This issue has not yet been determined by the United States Supreme Court
and Plaintiff is pleading this count in order to preserve this issue for potential review by the
United States Supreme Court and for potential reconsideration by the Seventh Circuit Court of
Appeals of its prior holdings.
28
be detained and prosecuted. Furthermore, the Defendant Officers intentionally withheld from and
misrepresented to prosecutors facts that further vitiated probable cause against Jesús as set forth
above, and failed to investigate evidence which would have led to the actual offender. The
Defendant Officers performed the above-described acts deliberately, with reckless disregard for
the truth, and with malice.
180. The prosecution of Jesús terminated in his favor.
181. The Defendant Officers’ actions directly and proximately caused the injuries and
damage to Jesús set forth above.
COUNT VII
State Law Claim for Malicious Prosecution
count.
Bush, Levy, Girard, Stewart and Glad, individually, jointly, and in conspiracy, initiated and
continued a malicious prosecution without probable cause against Jesús.
184. The prosecution of Jesús terminated in his favor.
185. The Defendants’ actions were done in a willful and wanton manner.
186. The Defendants’ actions directly and proximately caused the injuries and damage
to Jesús set forth above.
29
WHEREFORE, Jesús demands actual or compensatory damages against Defendants
Bieschke, Chiro, Conway, Connolly, Kopecky, Oropeza, Pinedo, Bush, Levy, Girard, Stewart
and Glad and, because these Defendants acted in a malicious, willful and/or wanton manner,
punitive damages, and such other and additional relief as this Court deems equitable and just.
COUNT VIII
State Law Claim for Violation of the Illinois Constitution, Article II, Section 10
count.
188. The actions taken by Defendants Bush, Connolly and Oropeza denied Jesús his
state constitutional right to protection against self-incrimination, as provided by the Illinois
Constitution, Article II, section 10, and were a direct and proximate cause of Jesús’ injuries as
set forth above.
WHEREFORE, Jesús demands actual and compensatory damages against Defendants
Bush, Connolly and Oropeza; and because they acted maliciously, wantonly, or oppressively,
punitive damages, plus the costs of this action, attorneys’ fees and such other and additional
relief as this court deems equitable and just.
COUNT IX
State Law Claim for Intentional Infliction of Emotional Distress
count.
Bush, Levy, Girard, Stewart and Glad individually, jointly, and in conspiracy, engaged in
extreme and outrageous conduct by, inter alia, coercing a false confession from Jesús and/or by
failing to prevent or stop Jesús’ coercive interrogation, by constructing and fabricating the
30
details of Jesús’ confession, and those of his alibi witnesses, Heladio, Collin and Leslie, and by
procuring his prosecution, conviction, and sentence of imprisonment for a murder he did not
commit by means of the false and fabricated confession, witness statements and evidence.
191. The individual Defendants individually, jointly, and in conspiracy, engaged in
additional extreme and outrageous conduct by fabricating and coercing inculpatory evidence, by
continuing Jesús’ false imprisonment after procuring his wrongful conviction, by refusing to
investigate or discipline the interrogators, and by covering up all of their individual and
conspiratorial actions as more fully alleged above in this Complaint.
Bush, Levy, Girard, Stewart and Glad intended to inflict severe emotional distress on Jesús, and
knew that their conduct would cause Jesús severe emotional distress.
193. As a direct and proximate result of the Defendant Officers’ outrageous conduct,
Jesús was injured and has experienced, and continues to experience, severe emotional distress,
including fear of spending the majority of his life in prison, nightmares, disruption of his sleep,
symptoms of post-traumatic stress disorder, anxiety, depression, and inability to focus or
concentrate.
damages, plus the costs of this action, and such other relief as this Court deems equitable and
just.
COUNT X
State Law Claim for Conspiracy
count.
31
Bush, Levy, Girard, Stewart and Glad with other unsued co-conspirators, including police and
prosecutorial investigative, supervisory, and command personnel, together reached an
understanding, engaged in and continue to engage in a course of conduct, and otherwise jointly
acted and/or conspired among and between themselves to falsely imprison Jesús and/or to
continue that imprisonment, to maliciously prosecute Jesús and/or continue that prosecution,
and to intentionally inflict severe emotional distress on Jesús.
196. In furtherance of this conspiracy or conspiracies, the Defendants named above,
together with their unsued co-conspirators, committed the overt acts set forth above.
197. The conspiracy or conspiracies were and are continuing in nature.
WHEREFORE, Jesús demands compensatory damages, jointly and severally from
Defendants Bieschke, Chiro, Conway, Connolly, Kopecky, Oropeza, Pinedo, Bush, Levy,
Girard, Stewart and Glad, and, because these Defendants acted in a malicious, willful and/or
wanton manner, for punitive damages, plus the costs of this action and whatever additional
relief this Court deems equitable and just.
COUNT XI
State Law Respondeat Superior Claim against the Village of Wheeling
count.
199. Defendants Bieschke, Chiro, Conway, Connolly, Kopecky, Oropeza, and
Pinedo, were, at all times material to this complaint, employees of Defendant Village of
Wheeling; were acting within the scope of their employment; and their acts, which violated state
law, are directly chargeable to Defendant Village of Wheeling under state law pursuant to
respondeat superior.
32
WHEREFORE, Jesús demands judgment against Defendant Village of Wheeling for any
and all compensatory damages awarded on Jesús’ state law claims against Defendants Bieschke,
Chiro, Conway, Connolly, Kopecky, Oropeza, and Pinedo, plus the costs of this action and
whatever additional relief this Court deems equitable and just.
COUNT XII
745 ILCS 10/9-102 against the Village of Wheeling
count.
201. Defendant Village of Wheeling was the employer of Bieschke, Chiro, Conway,
Connolly, Kopecky, Oropeza, and Pinedo at all times relevant and material to this complaint.
These Defendants committed the acts alleged above in the scope of their employment as
employees of the Village of Wheeling.
WHEREFORE, Jesús, pursuant to 745 ILCS § 10/9-102, and otherwise pursuant to law,
demands judgment against Defendant Village of Wheeling, in the amounts awarded to Jesús
against Defendants Bieschke, Chiro, Conway, Connolly, Kopecky, Oropeza, and Pinedo as
damages, attorneys’ fees, costs and interest, and for whatever additional relief this Court deems
equitable and just.
COUNT XIII
State Law Respondeat Superior Claim against the City of Evanston
count.
203. Defendants Bush and Levy were, at all times material to this complaint,
employees of Defendant City of Evanston; were acting within the scope of their employment;
33
and their acts which violated state law are directly chargeable to Defendant City of Evanston
under state law pursuant to respondeat superior.
WHEREFORE, Jesús demands judgment against Defendant City of Evanston for any
and all compensatory damages awarded on Jesús’ state law claims against Defendants Bush and
Levy, plus the costs of this action and whatever additional relief this Court deems equitable and
just.
COUNT XIV
745 ILCS 10/9-102 against the City of Evanston
count.
205. Defendant City of Evanston was the employer of Defendants Bush and Levy at
all times relevant and material to this complaint. These Defendants committed the acts alleged
above in the scope of their employment as employees of the City of Evanston.
demands judgment against Defendant City of Evanston, in the amounts awarded to Jesús against
Defendants Bush and Levy as damages, attorneys’ fees, costs and interest, and for whatever
additional relief this Court deems equitable and just.
COUNT XV
State Law Respondeat Superior Claim against the Village of Wilmette
count.
207. Defendant Girard was at all times material to this complaint, an employee of
Defendant Village of Wilmette; was acting within the scope of his employment; and his acts,
34
which violated state law, are directly chargeable to Defendant Village of Wilmette under state
law pursuant to respondeat superior.
WHEREFORE, Jesús demands judgment against Defendant Village of Wilmette for any
and all compensatory damages awarded on Jesús’ state law claims against Defendant Girard,
plus the costs of this action and whatever additional relief this Court deems equitable and just.
COUNT XVI
745 ILCS 10/9-102 against the Village of Wilmette
count.
209. Defendant Village of Wilmette was the employer of Defendant Girard at all
times relevant and material to this complaint. Defendant Girard committed the acts alleged
above in the scope of his employment as an employee of the Village of Wilmette.
demands judgment against Defendant Village of Wilmette, in the amount awarded to Jesús
against Defendant Girard as damages, attorneys’ fees, costs and interest, and for whatever
COUNT XVII
State Law Respondeat Superior Claim against the Village of Lincolnwood
count.
211. Defendant Stewart, was, at all times material to this complaint, an employee of
Defendant Village of Lincolnwood; was acting within the scope of her employment; and her
acts which violated state law are directly chargeable to Defendant Village of Lincolnwood under
state law pursuant to respondeat superior.
35
WHEREFORE, Jesús demands judgment against Defendant Village of Lincolnwood for
any and all compensatory damages awarded on Jesús’ state law claims against Defendant
Stewart, plus the costs of this action and whatever additional relief this Court deems equitable
and just.
COUNT XVIII
745 ILCS 10/9-102 against the Village of Lincolnwood
count.
213. Defendant Village of Lincolnwood was the employer of Defendant Stewart at all
times relevant and material to this complaint. This Defendant committed the acts alleged above
in the scope of her employment as an employee of the Village of Lincolnwood.
demands judgment against Defendant Village of Lincolnwood, in the amount awarded to Jesús
against Defendant Stewart as damages, attorneys’ fees, costs and interest, and for whatever
COUNT XIX
State Law Respondeat Superior Claim against the Village of Skokie
count.
215. Defendant Glad, was, at all times material to this complaint, an employee of
Defendant Village of Skokie; was acting within the scope of his employment; and his acts which
violated state law are directly chargeable to Defendant Village of Skokie under state law
pursuant to respondeat superior.
36
WHEREFORE, Jesús demands judgment against Defendant Village of Skokie for any
and all compensatory damages awarded on Jesús’ state law claims against Defendant Glad, plus
the costs of this action and whatever additional relief this Court deems equitable and just.
COUNT XX
745 ILCS 10/9-102 against the Village of Skokie
count.
217. Defendant Village of Skokie was the employer of Defendant Glad at all times
relevant and material to this complaint. Defendant Glad committed the acts alleged above in the
scope of his employment as an employee of the Village of Skokie.
demands judgment against Defendant Village of Skokie, in the amount awarded to Jesús against
Defendant Glad as damages, attorneys’ fees, costs and interest, and for whatever additional relief
this Court deems equitable and just.
JURY DEMAND
Jesús Sánchez demands trial by jury on all counts.
Respectfully submitted,
Dated: April 10, 2019

JESÚS SÁNCHEZ
By: /s/ Joey L. Mogul

One of his attorneys
Joey L. Mogul, John L. Stainthorp

Jan Susler, Christian Snow
People’s Law Office
1180 N. Milwaukee Avenue
Chicago, Illinois 60642
(773) 235-0070
Attorneys for Plaintiff Jesús Sánchez
37

Jesus Sanchez V Wheeling Et Al

Uploaded by

Jesus Sanchez V Wheeling Et Al

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Case: 1:19-cv-02437 Document #: 1 Filed: 04/10/19 Page 1 of 37 PageID #:1

IN THE UNITED STATES DISTRICT COURT

Police Department (“EPD”), Wilmette Police Department (WiPD), Lincolnwood Police

while incarcerated in jail and prison.

2. Jesús Sánchez was charged with killing Rafael Orozco after:

a. Defendants Bush, Oropeza and Connolly interrogated Jesús for close to 12

3. Jesús was wrongfully convicted of the murder of Rafael Orozco on November 7,

2014 and he was sentenced to serve 45 years in prison on December 8, 2014.

JURISDICTION AND VENUE

to the court’s supplemental jurisdiction, as codified in 28 U.S.C. § 1367(a).

Jesús’ claims also occurred in this judicial district.

8. Defendants Detective M. Bieschke, Sergeant Victor Chiro, Sergeant Michael

9. Defendant Village of Wheeling is an Illinois municipal corporation. The Village

of Wheeling is or was the employer of Defendants Bieschke, Chiro, Conway, Connolly,

Kopecky, Oropeza, and Pinedo.

sworn EPD officers at all times relevant to this Complaint.

11. Defendant City of Evanston is an Illinois municipal corporation. The City of

Evanston is or was the employer of Defendants Bush and Levy.

officer at all times relevant to this Complaint.

13. Defendant Village of Wilmette is an Illinois municipal corporation. The Village

of Wilmette is or was the employer of Defendant Girard.

times relevant to this complaint.

15. Defendant Village of Lincolnwood is an Illinois municipal corporation. The

Village of Lincolnwood is or was the employer of Defendant Stewart.

relevant to this complaint.

17. Defendant Village of Skokie is an Illinois municipal corporation. The Village of

Skokie is or was the employer of Defendant Glad.

defined under federal law.

A. The Shooting of Rafael Orozco

Illinois on May 1, 2013 at approximately 9:00 p.m.

courtyard under a streetlight when gunshots were fired.

responded to the scene.

B. Plaintiff Jesús Sánchez’s Location and Alibi Witnesses

Longacre subdivision, south of the Pleasant Run courtyard.

C. Jesús Sanchez’s Unlawful Detention

at approximately 10:20 p.m.

throughout the remainder of May 1 through May 2, 2013.

was transported to the WPD.

D. Jesús Sánchez’s Interrogation on May 1, 2013

Orozco on May 1, 2013 from 10:20 p.m. to 11:40 p.m.

E. Heladio Flores’ Interrogation on May 1, 2013

38. Defendants Bieschke and Detective McGuire interrogated Heladio from

approximately 10:40 to 11:56 p.m. on May 1.

40. During this initial interrogation, Heladio truthfully informed Defendant

F. The NORTAF Investigation of Rafael Orozco’s Murder

time he was shot.

G. Jesús Sánchez’s Interrogation on May 2, 2013 at 2:50 a.m.

Lane when heard the gunshots.

H. Heladio Flores’ Interrogation on May 2, 2013 at 3:36 a.m.

and Kopecky questioned Heladio a second time.

Pleasant Run apartment complex.

I. Bryan Estrada’s Interrogations on May 1 and 2, 2013

second time on May 2 from approximately 6 to 7:20 a.m.

years old but they interrogated him without his parents.

shots were fired.

murder of Rafael Orozco.

dark colored sedan - - suspected of being involved in the shooting.

incriminating statements, the Defendant Officers agreed to administer presumptive gunshot

residue (PGSR) tests to Jesús, Bryan and Heladio.

to whether an individual shot or held a gun.

63. In furtherance of the conspiracy, WPD Detective Conboy conducted a PGSR

at 6:44 a.m. on May 2, 2013.

the table in the interrogation room.

K. Jesús Sanchez’s Interrogation on May 2 at 7:50 a.m.

Jesús from 7:54 to 9:17 a.m.

indicating he was waiving his Miranda rights.

on May 1, in which he denied any involvement in the murder of Mr. Orozco.

that he shot and killed Mr. Orozco.

laid a chair on its side to use as a head rest.

L. Jesús Sanchez’s Interrogation on May 2 at 9:52 a.m.

inconsistent with his guilt.

M. Heladio Flores’ Interrogation on May 2 at 10:14 a.m.

from Heladio were false.

N. Heladio’s Interrogation on May 3

inconsistent with the physical evidence and witness accounts.

O. The Arrests and Interrogations of Alibi Witnesses Collin Scheffler, Leslie