On June 10, 2025, an Illinois appeals court overturned a $7 million personal injury verdict against Taft client the Chicago Housing Authority (CHA) and entered judgment in the CHA’s favor, ruling the CHA did not owe plaintiff Joseph Taylor a duty of care as a matter of law. Taylor was struck by a bullet fired by a security guard employed by AGB Investigative Services (AGB), an independent contractor providing security services at CHA properties. Taylor argued that the CHA was negligent because it failed to enforce contractual requirements that security guards possess at least three years of prior security experience, and failed to adequately oversee AGB. Taylor settled his claims against AGB and the security guard, and proceeded to trial against the CHA on a single negligence claim. A jury found in Taylor’s favor, awarding him $7 million in damages.

The three-judge panel held that the contractual requirements on which Taylor relied were internal standards that did not themselves create a legal duty. The appellate court further found that Taylor failed to show that his injury was a foreseeable consequence of CHA’s alleged failure to ensure the guard met the experience requirement, particularly because the shooting occurred during a pursuit unrelated to CHA property or residents. The court also concluded that the CHA did not retain sufficient control over AGB’s day-to-day operations to establish liability under the retained-control exception applicable to independent contractors. Because Taylor failed to establish that the CHA owed him a duty under the circumstances, the appellate court ruled that the CHA was entitled to judgment notwithstanding the verdict and reversed the circuit court’s judgment.

The case is Taylor v. Chicago Housing Authority, case number 1-24-0874, in the Appellate Court of Illinois, First District.

The CHA was represented on appeal by Taft attorneys Tim Eaton and Adam Decker.