Zander v. Carlson

Summary

The Illinois Supreme Court affirmed the dismissal of a police officer’s malpractice claim against his union‑assigned attorney and his duty‑of‑fair‑representation claim against the union, holding that the attorney is immune under Atkinson and that the union claim lies within the exclusive jurisdiction of the Illinois Labor Relations Board. The court also rejected the officer’s arguments that an attorney‑client relationship existed or that a third‑party‑beneficiary theory could overcome immunity.