Heyl Royster



Perkins and TeBeest Author IDC Article on Qualified Immunity for Government Contractors


Dave Perkins and Seth TeBeest authored an article entitled “Employee of Private Security Firm Granted Qualified Immunity in Section 1983 Action” for the Fourth Quarter edition of the IDC Quarterly. The article examines a 2017 decision of the Court of Appeals for the Seventh Circuit in the case of Meadows v. Rockford Housing Authority. In Meadows, the plaintiff alleged that he was improperly evicted by a private security firm hired by RHA. The question that was before the Seventh Circuit was whether the private security firm was entitled to the qualified immunity that would be afforded to RHA as a governmental entity – which the court answered in the affirmative. Perkins and TeBeest explain in the article that the level of supervision a governmental entity has over a private contractor is a defining factor for determining whether an employee of the private contractor will receive qualified immunity for his or her actions.

Matt Thompson is the Executive Editor of the IDC Quarterly – the official publication of the Illinois Association of Defense Trial Counsel – John Heil is an IDC board member, and Craig Unrath is chair of the IDC’s Amicus Committee.