Robinson v. Village of Sauk Village

Summary

The court held that absolute immunity for injuries inflicted by an escaped or escaping prisoner applies only when police directly restrict or control the person's freedom of movement to a particular place. Because the fleeing driver remained free to drive away from the church parking lot despite the officers' weapons and commands, he was not held in custody when he later struck the plaintiff. The court affirmed the appellate court, reversed the circuit court's summary judgment, and remanded for further proceedings.