A federal judge this week dismissed a lawsuit claiming that a protest against Israel’s bombardment of Gaza that shut down a Chicago highway amounted to “false imprisonment.”
The judge also ordered sanctions against the Indiana lawyer who brought the lawsuit, saying it was “intended to harass” rather than make legitimate legal claims.
Christopher Manhart filed the suit over a protest in April 2024 that shut down Interstate 190 near O’Hare Airport, naming various activist groups and individuals as defendants. Manhart claimed the blockade forced him to miss a flight and, as a result, “an important work dinner and networking session.”
Manhart also claimed the activists acted as a “propaganda arm” of Hamas and that the protesters were responsible for extending the war in Gaza.
In her ruling Thursday, U.S. District Judge Mary Rowland wrote that Manhart’s lawsuit was “only a hair’s breadth away from calling Defendants terrorists and placing the loss of innocent lives at their feet.”
Rowland also wrote that stopping the flow of traffic didn’t amount to false imprisonment, and that Manhart had other options for getting past the blockade. Other people stuck in traffic left their cars and walked to the airport, the judge noted.
“The Court does not doubt that Plaintiff felt trapped in his car and in fact could not easily go where he wanted to,” Rowland wrote. “His frustrations were no doubt exacerbated because he was on the way to the airport.
“But to state claim for false imprisonment, the confinement must be ‘involuntary;’ it is not enough for a plaintiff to voluntarily remain in a place even if they believe they are justified in doing so.”
Sheila Bedi, an attorney for the defendants, said the case could have set a dangerous precedent, allowing anyone inconvenienced by a traffic stoppage to sue.
“If the plaintiffs had prevailed here, any time there was a foreseeable traffic jam, whether it was because of a Bears game or Beyonce concert or a protest, those individuals who … were responsible for the traffic jam could then be held liable in tort for false imprisonment,” Bedi said. “It’s a ridiculous legal theory.”
The judge also rejected Manhart’s claim that he was “injured” by the protesters’ actions.
“Plaintiff’s alleged injuries are that he was caught in traffic for a few hours and missed a networking event,” Rowland wrote in her ruling. “These are not matters of public safety.”
Manhart’s attorney, Ted Frank of the Hamilton Lincoln Law Institute, said the judge’s decision and sanctions were “based on the premise that it’s legal in Illinois for drivers to abandon their car on the highway outside O’Hare Airport for up to seven days, and thus victims weren’t truly trapped.”
“This is a regrettable misreading of the precedent and the applicable statutes, and we are confident in our chances on appeal,” Frank said in a statement. “The court found the attorneys acted for an improper purpose because our complaint expressed outrage against what we continue to believe was intentionally outrageous wrongful behavior that merits punishment by the criminal and civil justice system.”
Manhart’s attorneys filed a notice of appeal on Friday. Manhart declined to comment.
Bedi runs the community justice clinic at Northwestern University’s law school. The justice clinic’s role in the lawsuit helped draw the attention of a Republican-led congressional committee earlier this year that accused the Evanston school of using taxpayer funds to “engage in progressive-left political advocacy.”
Bedi said she hoped the judge’s decision makes clear “to the other powers that be” that the lawsuit was improper and the legal clinic did the right thing in taking up the case.
“The other takeaway from this, from the moment we’re in, is that the federal courts are not completely lost for those of us who want to defend the right to dissent and to defend democratic values,” Bedi said.