G. Flint Taylor

The Wilson record

In 1993, the Seventh Circuit reviewed an internally inconsistent civil verdict. A jury had found that Andrew Wilson’s constitutional rights were violated, while exonerating every officer and finding that a Chicago policy authorizing abuse of people suspected of killing or injuring police officers had not caused what happened to him. The central issue was who had violated his rights. G. Flint Taylor and John L. Stainthorp were identified as counsel who argued Wilson’s appeal.

Wilson remained convicted of murdering Chicago police officers William Fahey and Richard O’Brien. The Illinois Supreme Court had reversed his first conviction because his confession was coerced; after a retrial he was again convicted and received a life sentence. In his federal suit under 42 U.S.C. § 1983, the civil jury had to decide whether officers, including Jon Burge, had tortured him in custody, independently of his murder convictions.

The second civil trial had allowed the defense to place the murders before the jury in graphic detail. At the same time, the trial judge excluded Melvin Jones, who said Burge and other officers had subjected him to electric shock nine days before Wilson’s interrogation, and Donald White, who said the same officers had beaten him while investigating those murders. The appellate court held that the details of Wilson’s crimes had overwhelmed the question the jury was supposed to decide, while the excluded accounts were relevant to intent, opportunity, preparation, plan, and impeachment.

The Seventh Circuit also upheld two trial rulings. It sustained the exclusion of a proposed torture expert because the trial judge could reasonably find that the witness had not established the necessary expertise. On rehearing, it affirmed a directed verdict for Officer Michael McKenna after correcting its understanding of when that ruling had been entered.

The Seventh Circuit nevertheless left the judgment for Chicago in place. Superintendent Richard Brzeczek had received complaints about abuse in Area 2 and referred them to an internal unit that lost many of them. The record could show an inadequate response, even gross carelessness, but it did not show that Brzeczek approved the practice. Municipal liability required proof that a final policymaker adopted or approved the practice.

Building proof across cases

Taylor’s early civil-rights practice included Hampton v. Hanrahan. He was one of six lawyers listed for the plaintiffs on appeal after an eighteen-month civil trial arising from the 1969 raid that killed Fred Hampton and Mark Clark and wounded four other Black Panther Party members. The trial produced roughly 37,000 pages of testimony. After the jury deadlocked, the district judge directed verdicts for the defendants and assessed costs against the plaintiffs.

The Seventh Circuit reversed as to most defendants. Its opinion organized the evidence in three periods—before the raid, the raid itself, and what followed—and held that the trial judge had weighed evidence in the defendants’ favor when the jury should have been allowed to decide it. The ruling returned the liability questions for a new trial. The Supreme Court later held that the plaintiffs were not yet prevailing parties entitled to interim fees at that stage.

George Jones’s civil suit concerned Chicago detectives’ clandestine “street files,” kept outside the regular investigative files sent to prosecutors. Those files could contain exculpatory material unavailable to the defense. Jones had been arrested, jailed, and prosecuted for murder before the charges were dropped. A jury awarded him $801,000, and the Seventh Circuit listed Taylor as his lawyer on appeal.

The appellate court affirmed the judgment on the merits. It concluded that the evidence supported a conspiracy to railroad Jones and that the department-wide, long-standing street-file practice could be treated as a City custom consciously approved at the highest policymaking level. Jones and Wilson reached different municipal-liability results. In Jones, the hidden system itself connected the injury to municipal practice. In Wilson, evidence that abuse was common and complaints were mishandled did not establish the required approval by the identified policymaker.

Taylor also worked on the legal shields that can stop a damages case before a jury reaches the underlying conduct. In Cleavinger v. Saxner, the Supreme Court identified him as counsel for two federal prisoners who had won due-process verdicts against members of a prison disciplinary committee. The Court held that the committee members had only qualified immunity, not the absolute immunity they claimed. Their official titles did not make their function equivalent to that of an independent judge.

Eight years later, Taylor argued Buckley v. Fitzsimmons for a § 1983 plaintiff who alleged that prosecutors had fabricated evidence during an investigation and made defamatory statements at a press conference. The Supreme Court held that the prosecutors were not absolutely immune for those functions. When prosecutors performed investigative work of the kind detectives perform, the Court said, they received the same immunity; speaking to the press likewise had no functional tie to the judicial process.

Cleavinger and Buckley limited absolute immunity for prison disciplinary officials and prosecutors acting outside their judicial roles. To recover damages, a plaintiff still had to identify the act, the official’s function, personal participation, and the causal path to injury. Taylor’s cases developed that proof through concealed memoranda, excluded witnesses, and evidence of what each official did.

The limits of a civil judgment

Wilson’s appeal produced a new trial against Burge. On remand, judgments were entered against Burge for $50,000 in compensatory damages and $400,000 in attorney’s fees. Chicago had no direct municipal-liability judgment against it. By then the City had announced that it would not pay and Burge apparently lacked assets, so Wilson brought Chicago back into the case under an Illinois statute directing local governments to pay judgments for employees acting within the scope of their employment.

The Seventh Circuit affirmed the City’s payment obligation in 1997. It held that Burge had acted within the scope of his police employment when he extracted confessions by improper means and that federal ancillary jurisdiction allowed the court to decide the related indemnification claim before the litigation ended. The ruling gave the civil judgment a solvent source of payment.

Chicago therefore paid through indemnification rather than direct municipal liability. It had prevailed on the claim that its own policy caused Wilson’s constitutional injury, but state law made the employer answer for Burge’s judgment because he acted within the scope of his police employment.

Other proceedings continued to test the same body of evidence. Chicago’s Police Board fired Burge in 1993 after finding that he had used torture. A later special-prosecutor investigation concluded that Burge and officers under his command likely had committed torture but that prosecution for those acts was barred by the state limitations period. Evidence concerning Area 2 torture was developed across survivor accounts, civil cases, disciplinary proceedings, investigations, journalism, and public advocacy.

A separate § 1983 suit filed by Madison Hobley supplied the statements that eventually supported federal charges. In written discovery in 2003, Burge denied using coercive techniques or knowing that other officers had done so. The federal indictment alleged that those answers were false and that they obstructed the civil proceeding. The later federal prosecution drew on statements Burge made in Hobley’s civil case and on evidence developed across years of related litigation.

A federal jury convicted Burge in 2010 of two obstruction counts and one perjury count, and he received a 54-month sentence in 2011. The Justice Department stated that the case concerned lies about torture, while its sentencing release again noted that the underlying abuse was outside the limitations period. The charges and verdict were confined to obstruction and perjury and did not adjudicate every survivor’s claim.

Reparations and what followed

The remaining injuries required remedies beyond a single damages award. Some survivors had no viable civil claim because too much time had passed. Some had received settlements, while others were still contesting convictions or seeking recognition. The reparations campaign answered that unevenness through a public measure broad enough to address a shared history.

The 2015 agreement was collective work. Survivors and organizers had pressed the issue for years; Chicago Torture Justice Memorials, Black People Against Police Torture, Amnesty International, aldermen, and other advocates carried the campaign. Joey Mogul drafted the original ordinance. The City identified Mogul and Taylor among the negotiators; Taylor worked within the survivor-led coalition in negotiations with the City’s corporation counsel.

Chicago approved a $5.5 million fund together with nonfinancial measures: a formal acknowledgment, counseling and other services, access to City Colleges and job training for eligible survivors and family members, a curriculum about the torture cases, and a permanent memorial. An administrative eligibility process determined access to the program, which paired payments with services, education, and public memory.

Implementation identified recipients through administrative review. The City reported in January 2016 that 98 people had applied and that 59 survivors and families would begin receiving reparations.

The Illinois Torture Inquiry and Relief Commission continues a different part of the work. Its current mandate is to investigate fairly claims that torture produced confessions leading to convictions and to provide a route to relief where warranted. The Commission also states that it must reject meritless claims when a conviction was soundly obtained without a coerced confession. In 2016, its jurisdiction expanded beyond officers connected to Burge.

In July 2026, survivors, advocates, and City officials broke ground in Washington Park on the permanent memorial promised by the 2015 reparations package. The ceremony began construction eleven years after the City made that commitment. It followed trials, appeals, disciplinary proceedings, civil discovery, a federal perjury prosecution, organizing, negotiation, and administrative review.