Sara Lee Ellis
How Judge Ellis decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
She reads insurance policies as an integrated whole and will enforce an exclusion even where a key blank was left unfilled, so long as the same sentence supplies the operative definition. A contract that requires the reader to consult multiple pages to reach a clear answer is not thereby ambiguous; she gives unambiguous language its plain meaning rather than construing against the drafter.
“That the Policy requires a reader to consult multiple pages to reach an otherwise clear answer does not render the Policy ambiguous. ... the only reasonable interpretation is that the effective date was March 1, 2019, the date the premium was paid and the Policy delivered.”
On a prisoner Eighth Amendment deliberate-indifference claim she assesses the totality of the treatment, not isolated delays, and requires independent (expert or medical-record) evidence that a scheduling delay -- as opposed to the underlying condition -- exacerbated the injury. A medical provider's care is accorded deference absent a substantial departure from accepted professional judgment.
“a plaintiff must also provide independent evidence that the delay exacerbated the injury or unnecessarily prolonged pain. ... nothing in the record would allow a trier of fact to attribute the delay in Campbell's two orthopedic appointments to Dr. Obaisi.”
She follows the Dial A Car rationale: a plaintiff cannot use the ICFA or IUDTPA (the state equivalents of the Lanham Act) as a 'backdoor' to have a federal court declare a defendant's conduct illegal under a municipal ordinance the local commission has not yet interpreted. But she carefully severs those barred theories from independent misrepresentation claims, which survive.
“the Court agrees with the D.C. Circuit and finds that Alsubbah cannot use the ICFA or the IUDTPA 'as a backdoor method' to bring a claim that Uber violates Chicago taxi and livery regulations.”
Procedural preferences
She construes pro se complaints liberally and will even consider 'extra assertions' raised in a brief opposing dismissal where they are consistent with the complaint -- but liberal construction does not save claims that fail as a matter of law (e.g., a statute that limits liability rather than imposing a duty, or a private right of action that does not exist).
“A plaintiff may 'supplement' the complaint with 'extra assertions' in a memorandum opposing a motion to dismiss. ... Because Fifth Third cannot breach an obligation it does not have, the Court dismisses McGee's breach of contract claim.”
On summary judgment she will draw an adverse inference from a civil defendant's invocation of the Fifth Amendment (including against a corporation through its stipulated Rule 30(b)(6) deponent), but the movant must still introduce affirmative evidence of each element -- silence alone is a relevant factor, never a substitute for proof, and she leaves genuinely disputed elements (here, conspiracy and one defendant's receipt of funds) for the jury.
“a party may not rest on the adverse inference alone: 'Silence is a relevant factor to be considered in light of the proffered evidence, but the direct inference of guilt from silence is forbidden.'”
Cautions
A constructive trust requires an identifiable fund traceable to the wrongful conduct; she will not impose one where the plaintiff only shows the defendant was unjustly enriched but cannot point to specific traceable property. Counsel seeking equitable remedies should plead and prove the res, not just the enrichment.
“Because there is not an identifiable fund to which the amount by which Larisa was unjustly enriched can be traced, the Court will not impose a constructive trust on any funds or property in Larisa's possession.”
A declaratory-judgment claim survives a motion to dismiss only where it presents a real, ripe controversy over future rights and is not merely duplicative of an available breach-of-contract remedy. She will keep a declaratory action that settles post-termination obligations the defendant refuses to honor, but signals it may become redundant once a damages claim could provide full relief.
“Because an actual case or controversy exists and PCH has adequately pleaded facts to state a claim under the Federal Declaratory Judgment Act, ... the Court denies the motion.”
Motion outcomes
Counted from classified signed orders only. Percentages are shown only where the sample is large enough to be meaningful; smaller samples are reported as raw counts.
| Motions to dismiss N = 4 |
Granted: 2Granted in part: 1Denied: 1 | counts only |
| Summary judgment N = 2 |
Granted: 1Granted in part: 1 | counts only |
A "1 of 1" is one ruling, not a tendency. Treat small samples as illustrative, not predictive.
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“For the foregoing reasons, the Court grants Pruco's motion to dismiss [11]. The Court dismisses the complaint with prejudice and terminates the case.”
“For the foregoing reasons, the Court grants Fifth Third's motion to dismiss [42]. The Court terminates as moot McGee's other pending motions [40], [44].”
“For the foregoing reasons, the Court denies the motion to dismiss [16]. Healogics is ordered to answer the complaint by June 15, 2016.”
“Uber's motion to dismiss [8] is granted in part and denied in part. The Court dismisses Plaintiffs' allegations that Uber operates illegally and misrepresents the illegal nature of its services. Count III is dismissed in its entirety ... the Court denies the motion to dismiss with regard to Count I's allegations ... and Count II's allegations.”
“For the foregoing reasons, the Court grants Defendants' motion for summary judgment [40]. The Court enters judgment for Defendants on Campbell's amended complaint and terminates this case.”
“For the foregoing reasons, Chicago Title's motion for summary judgment [134] is granted in part and denied in part. Summary judgment is entered against Elvir Sinikovic on the claims for breach of fiduciary duty (Count I), unjust enrichment (Count III), and accounting (Count IV). ... A constructive trust is imposed on the $40,000 invested by DC&L in the property located at 2925 W. Touhy, Unit 3, Chicago, Illinois.”
Caseload & timing
From public federal docket records for this judge.
Recent (2025-2026) docket shows a mix typical of an active N.D. Ill. judge: civil rights / Sec. 1983 (Bracey v. Lake County, Foster v. Feliciano, Cunningham v. Rodriguez), prisoner suits (Knox v. IDOC), employment (Berry v. Univ. of Illinois at Chicago), human-trafficking/TVPA (C.S. v. O'Hare Airport Hotel LLC), commercial contract (Contract Manufacturing Services v. RB Global; Van Horst v. United Rentals; Dworkin v. Tandem PES), and criminal (United States v. Mays). Her written-opinion docket sampled here spans insurance, consumer credit/FCRA, prisoner Eighth Amendment, declaratory judgment, ICFA/IUDTPA consumer fraud, and embezzlement/fiduciary-duty. Nature-of-suit is only partially reported in docket case-level metadata.