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101 Tex. L. Rev. Online 1 (2022)

handle is hein.journals/seealtex101 and id is 1 raw text is: Texas Law Review Online Volume 101 Response Incrementalism and Police Reform Stephen Rushin* Introduction Professor Teressa Ravenell's provocative new article, Unidentified Police Officials,' offers a carefully conceived analysis of the challenges facing civil litigants in some police-misconduct cases, particularly those involving so-called John Doe officers. In these John Doe cases, the identity of an officer who caused a constitutional violation is unknown.2 As she illustrates, these John Doe cases represent a surprisingly large number of cases in the context of civil rights violations-18.73% of cases filed in Georgia, 5.61% of cases filed in Illinois, and 19.28% of cases filed in Washington, according to her calculations.3 As Professor Ravenell illustrates through various real-world examples, litigants' inability to identify the officer responsible for a constitutional violation may impede their ability to collect damages.4 Take as an example Colbert v. City of Chicago,5 one of the cases discussed in her article.6 There, the plaintiff claimed that the Chicago police officers violated his Fourth Amendment right to be free from unreasonable search and seizure when they handcuffed him and ransacked * Stephen Rushin is the Associate Dean of Academic Affairs and the Judge Hubert Louis Will Professor of Law at Loyola University Chicago School of Law. Ph.D. and J.D., University of California, Berkeley. 1. Teressa Ravenell, Unidentified Police Officials, 100 TEXAS L. REV. 891 (2022). 2. Id. at 897-99 (describing this phenomenon, stating that 'John Doe' is perhaps the best- known pseudonym for a person whose identity is unknown and describing the use of this term in litigation). 3. Id. at 898 (showing these figures among data on the frequency of John Doe cases in a variety of litigation contexts). 4. Id. at 899-904 (providing a detailed explanation of this phenomenon and further describing how litigants have to sue the municipality in these cases because they cannot identify the official involved). 5. 851 F.3d 649 (7th Cir. 2017). 6. Ravenell, supra note 1, at 921-23 (explaining the case in the context of the Article's argument).

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