Full opinion text
MEMORANDUM OPINION AND ORDER REBECCA R. PALLMEYER, United States District Judge Plaintiffs are three employees of the Cook County Sheriffs Office who, during Todd Stroger’s term as Cook County Board President, held the title of “security specialist” and provided driving and protection services for Mr. Stroger. After Defendant Toni Preckwinkle was elected Cook County Board President, Preckwin-kle wanted no members of Stroger’s security detail to continue on-her detail. Defendant DeWayne Holbrook, then the Chief of Police for the Cook County Sheriffs Office, transferred Plaintiff Luis San-toyo from the security detail to a patrol position. Gary Hickerson, within the Department of Corrections, transferred Plaintiffs Elliotte Greene and Marlon Jones to their previous positions within the Department of Corrections. Plaintiffs filed this § 1983 suit against Cook County; Toni Preckwinkle, in her individual capacity as the Cook County Board President; the Cook County Sheriffs Office; and DeWayne Holbrook in his individual capacity as the Chief of Police for the Cook County Sheriffs Office, alleging that Defendants demoted Plaintiffs based on political considerations in violation of Plaintiffs’ First and Fourteenth Amendment rights. Defendants seek summary judgment. In their motion [72], Defendants DeWayne Holbrook and the Cook County Sheriffs Office (“Sheriffs Office Defendants”) argue (1) that the security specialist position is exempt from First Amendment protections because it is a confidential position, and (2) that Plaintiffs have not established a prima facie case of political retaliation. Defendants Toni Preckwinkle and Cook County (“County Defendants”) have moved independently for summary judgment [77], similarly arguing that the position is exempt from First Amendment protections and that Plaintiffs have not established a prima facie case. County Defendants also urge that Toni Preckwinkle is entitled to qualified immunity. The court concludes that Sheriffs Office Defendants’ motion for summary judgment [72] must be denied. County Defendants’ motion for summary judgment [77] is granted in part and denied in part. Defendants have not established that, as a matter of law, security specialists are confidential positions, and Plaintiffs have presented sufficient evidence to support a pri-ma facie case of retaliation. Because Plaintiffs’ right not to lose their job assignments for political reasons was not clearly established, however, Toni Preckwinkle is entitled to qualified immunity. BACKGROUND Plaintiffs Greene, Jones, and Santoyo are employees of the Cook County Sheriffs Office. Santoyo began working for the Sheriffs Office in 1995, Greene in 1999, and Jones in 2005; each one started out in the Department of Corrections as Correctional Officers. (Pis.’ Resp. to CCSO Defs.’ Local R. 56.1 Statement of Facts [86], hereinafter “Pis.’ Resp. to CCSO SOF,” ¶¶ 5-7.) Santoyo was promoted to the Sheriffs Police in 1997 and Greene was promoted to Correctional Sergeant within the ■ Department of Corrections in 2004. (Pis.’ Resp. to CCSO SOF ¶¶5, 7.) All three Plaintiffs were assigned to Stroger’s security detail and served in that capacity until Stroger’s term ended on December 6, 2010. (Pis.’ Local R. 56.1 Statement of Additional Material Facts in Opp. to Cnty. [85] hereinafter “Pis.’ SAF to County,” ¶ 20.) The detail operates as a hybrid entity reporting to supervisors in both the Cook County Board President’s office and the Cook County Sheriffs Office. Though the Cook County Sheriffs Office is not mandated by any ordinance or state statute to provide security specialists, (Pis.’ Resp. to CCSO SOF ¶ 34), the security detail is composed of Sheriffs Office employees who remain employed by the Cook County Sheriffs Office (and paid out of the Sheriffs budget), but report to a director of the detail. (Pis.’ Resp. to County Defs.’ Local R. 56.1 Statement of Facts [83], hereinafter “Pis.’ Resp. to County SOF,” ¶¶ 32, 48; Organizational Chart, Ex. 21 to Pis.’ Appendix [89-21], hereinafter “Org. Chart,” 3.) The director of the detail in turn reports to the Cook County Board President. (Org. Chart at 3; County Defs.’ Resp. to Pis.’ SAF [91], hereinafter “County Resp. to SAF,” ¶ 9.) The Chief ■ of Police of the Cook County Sheriffs Office also retains authority over any police officers assigned to the detail. (County Resp. to SAF ¶ 8.) 1. Todd Stroger’s security detail Todd Stroger was elected Cook County Board President in November, 2006. (Dep. of Elliotte Greene, Ex. 2 Pis.’ Appendix [89-2], hereinafter “Greene Dep.,” 12:8-9.) During Mr. Stroger’s campaign, from about August through November of 2006, Plaintiffs Greene and Jones volunteered one day a week as drivers and security specialists. (Pis.’ Resp. to CCSO SOF ¶ 12.) Greene and Jones were both employed by the Department of Corrections at the time (Greene as a Correctional Sergeant and Jones as a Correctional Officer) and performed this volunteer work on their days off. (Pis.’ Resp. to CCSO SOF ¶¶ 5-6, 12.) Shortly after Stroger’s election, Stroger’s Chief of Staff, Lance Tyson, called Brian Towne, then the Sheriffs Director of Administration, to request that the Sheriffs Office assign Greene to his security detail. (Pis.’ Resp. to CCSO SOF ¶ 15.) About a year and a half later, on May 8, 2008, another position on the detail opened up, and Lance Tyson requested that Jones fill that position. (Pis.’ Resp. to CCSO SOF ¶ 20; Pis.’ Resp. to County SOF ¶ 10.) The parties dispute the reasons for these openings on the detail: Plaintiffs assert that the positions became available after a previous member of the detail retired. (Pis.’ SAF to County ¶ 20.) According to County Defendants, Greene replaced Elmer Frazier, a member of the detail “who was removed when Bobby [sic] Steele left office.” (County Resp. to SAF ¶ 20.) The parties do not say who made the decision to remove Mr. Frazier. (See County Resp. to SAF ¶ 7 (“Elmer Frazier was removed before Todd came in to make room for Elliotte Green [sic]”); County SOF ¶ 56 (“Frazier was taken off the detail before Todd Stroger came in”).) County Defendants assert that Jones replaced a member of the detail who was removed at Todd Stroger’s request because Stroger’s wife did not like his driving. (County Resp. to SAF ¶ 20.) The parties do agree that in each case, the Sheriffs Office honored the President’s Office request and completed the transfer to assign Greene and Jones to the detail. (Pis.’ Resp. to CCSO SOF ¶ 35; Pis.’ Resp. to County SOF ¶ 51.) In July, 2008, another member of the security detail retired, and Luis Santoyo took his place. (Pis.’ Resp. to CCSO SOF ¶ 15.) Unlike Greene and Jones, Santoyo had not worked for Todd Stroger’s campaigns before being selected for the detail. (Dep. of Luis Santoyo, Ex. 1 to Pis.’ Appendix [89-1], hereinafter “Santoyo Dep.,” 21:23-22:15.) Phil Stephens, the director of the detail at that time, had previously worked with Santoyo in the Detective Unit of the Sheriffs Police; Stephens recommended Santoyo for the job and ultimately called to offer him the position. (Pis.’ Resp. to CCSO SOF ¶ 21; Santoyo Dep. at 12:15-13:2.) Before serving on Stroger’s security team, Santoyo had been working temporarily as a patrol officer in the Police Department, though he spent the previous four years in the Special Operations Unit and technically remained assigned to that unit. (Santoyo Dep. at 10:5-11.) Santoyo testified that he requested the patrol assignment because he expected to move to Florida — he does not specify when — and transferring from patrol would be smoother; had he remained in Special Operations until he left, he would have needed to return to Chicago to testify even after the move. (Id. at 10:9-11:6.) But the Florida plans fell through, so Santoyo accepted the positon on the Stroger security detail. (Id. at 10:11-11:6.) The procedure used to hire the three Plaintiffs — someone from the President’s office, either Lance Tyson or Phil Stephens, would call the Sheriffs Office to request a particular assignment — was the procedure used throughout Todd Stroger’s term for security detail appointments. (Pis.’ Resp. to County SOF ¶¶ 50-51.) It is undisputed that if the President expressed, a preference, the Sheriffs Office generally deferred to the President’s choices. (Pis.’ Resp. to CCSO SOF ¶ 35; Pis.’ Resp. to County SOF ¶¶ 61, 54.) When Plaintiffs were assigned to the security detail, they remained Sheriffs Office' employees, but received a higher rate of pay in return for longer hours and loss of eligibility for overtime pay. (Pis.’ Resp. to County SOF ¶ 36; CCSO Defs.’ Local R. 56.1 Statement of Facts in Support of Summ. J. [74], hereinafter “CCSO SOF,” ¶¶ 37-38.) Plaintiffs contend that their positions on the detail constituted a promotion and a raise. (Pis.’ Local R. 56.1 Statement of Additional Material Facts in Opp. to CCSO [88], hereinafter “Pis.’ SAF to CCSO,” ¶ 21.) The exact amount of the pay difference is unclear, however: Santoyo testified that the person currently in charge of the security detail receives an annual salary that is $26,000 greater than Santoyo’s current salary. (Santoyo Dep. at 60:8-19.) His own annual salary dropped $8,000 to $9,000 after being transferred from the detail, Santoyo maintains. (Id. at 45:21-46:3.) Greene testified that his current salary is $72,900, and that the salary he earned while assigned to the security detail was “[l]ess or more — no, I think more, I think I was making seventy-three with— I’d have to look at a piece of paper to recall.” (Greene Dep. at 99:14-22.) Like Greene, Jones could not specifically recall the pay differential. (Dep. of Marlon Jones, Ex. 3 to Pis.’ Appendix [89-3], hereinafter “Jones Dep.,” 19:4.) Brian Towne, The Sheriffs Chief of Staff, explained the source of the confusion: Their salaries were higher than their merit rank, I believe. It depends on what your seniority is, and the police officers make more money than correctional officers but, you know, the security specialists wouldn’t be receiving overtime ... and I think because of the long and unexpected hours, weekends and stuff that that’s where the higher salary was, but I don’t know if you broke it down by hour — by hourly wage, I wouldn’t know if I would call that a promotion. (Dep. of Brian Towne, Ex. 9 to Pis.’ Ap7 pendix [89-9], hereinafter “Towne Dep.,” 44:20-45:7.) II. Plaintiffs’ reassignment Todd Stroger ran against several candidates in the 2010 Democratic primary and ultimately lost to Defendant Toni Preck-winkle. (Pis.’ Resp. to County SOF ¶ 62.) The race was hotly contested and generated substantial ill will between Preekwinkle and Stroger. Stroger described their relationship as “frosty” and elaborated that the two had a “let’s-not-speak arrangement.” (Pis.’ Resp. to County SOF ¶ 62.) Defendants Preekwinkle and Cook County assert that members of Stroger’s transition team “either refused to cooperate, refused to speak with them, or gave them bad information.” (Defs.’ Preekwinkle and Cook Cnty.’s Local R. 56.1 Statement of Facts in Supp. of Summ. J. [76], hereinafter “County SOF,” ¶ 66) Accordingly, President Preckwinkle’s administration “had no reason to believe that Todd Stro-ger’s security detail who were with him 24/7 would be loyal or trustworthy.” (County SOF ¶ 66.) Exactly how the decision to transfer Plaintiffs from the detail came about is not clear. Brian Towne, the Chief of Staff for the Sheriffs Office, and John Keller, Preckwinkle’s Chief of Staff, had a series of conversations in which they discussed the future of the security detail. (County SOF ¶ 71; CCSO SOF ¶44.) Through Keller, President Preekwinkle made clear to Brian Towne that she did not want to keep Todd Stroger’s people on the detail and instead wanted to bring in her “own people.” (Pis.’ Resp. to CCSO SOF ¶¶ 42-43, 46.) Towne maintains that he repeatedly urged Keller to put the security detail in the Cook County Board President’s budget, in order to reduce financial strain on the Sheriffs Office and to clarify precisely who had authority over the members of the security detail. (CCSO SOF ¶ 45; Towne Dep. at 31:6-23.) As Keller recalls, however, it was Towne who first asked whether Preekwinkle wanted to bring in her own security team, and Keller confirmed that he and Ms. Preekwinkle would prefer to do so, but only “if it was possible” under the existing personnel rules, because Keller was uncertain whether the President had authority to replace the detail. (County SOF ¶ 72; Dep. of John Keller, Ex. 12 to Pis.’ Appendix [89-12], hereinafter “Keller Dep.,” 58:1-59:24.) According to Keller, Towne assured him that every new President selected his or her own detail, and the President’s Office relied on this representation. (County SOF ¶ 72.) Keller further emphasized that he and President Preekwinkle would have only done something had we been told we could. And so our recollection is that it didn’t come up specifically that they were Shakman [protected by the ban on political hiring and firing] or not Shakman, but that we were told that we could ... that there was the possibility of having our own people, and that they [the Sheriffs Office] were going to, you know, avail me of whatever processes that they had to make it happen. (Keller Dep. at 68:13-21.) Regardless of who brought up the topic first, as a result of these conversations, a few days before Preekwinkle was sworn in, Towne advised the Sheriffs Office that Preekwinkle did not want Plaintiffs on the detail. He also notified Rosemarie Nolan, the personnel director for the Sheriffs Office, that the Plaintiffs’ assignment to the detail was ending and that they needed to be reassigned to new positions. (Pis.’ Resp. to CCSO SOF ¶ 49.) The Plaintiffs were notified of their transfers rather abruptly. On December 6, 2010, the morning President Preckwin-kle assumed the position of Cook County Board President, Plaintiffs were denied access to the security office in the County building. (Pis.’ Resp. to CCSO SOF ¶ 59; County Resp. to SAF ¶ 22.) Plaintiffs Greene and Jones had picked up President Stroger from his house and driven him, per their normal routine, to the County building for Toni Preckwinkle’s swearing-in ceremony. (County Resp. to SAF ¶ 22; CCSO Defs.’ Resp. to Pis.’ SAF [95], hereinafter “CCSO Resp. to SAF,” ¶ 22.) They provided security services during the ceremony, and then left the meeting early with Todd Stroger and drove him to breakfast. (See Pis.’ Resp. to County SOF ¶¶ 20-21.) Plaintiffs assert that they left the meeting to go to breakfast “because they were still protecting the former County Board President” but returned after, expecting to resume their jobs for President Preckwinkle. (Pis.’ Resp. to County SOF ¶ 21.) When they returned, they were denied access to the security office on the fifth floor of the County building. (See Pis.’ Resp. to County SOF ¶ 22.) Confused, Greene and Jones reported to several different offices, eventually learning from Rosemarie Nolan, the Personnel Director for the Sheriffs Office, that they had been removed from the detail and would be reassigned to positions in the Department of Corrections. (Pis.’ Resp. to CCSO SOF ¶ 61.) Luis Santoyo arrived at the County building separately and was also denied entry to the security office on the fifth floor. (Santoyo Dep. at 39:1-8.) Santoyo then called Defendant DeWayne Holbrook, who was serving as the Chief of Police for the Cook County Sheriffs Office at that time. (County Resp. to SAF ¶ 23.) Hol-brook confirmed that Santoyo was being transferred from the detail because “they got their own people.” (Id.) Santoyo had hoped to return to Special Operations rather than his patrol position, but Hol-brook told him that was not an option. (Santoyo Dep. at 70:4-7.) According to Holbrook, the Sheriffs Office needed more patrol officers because the office “was short through attrition and other things.” (Dep. of Dewayne Holbrook, Ex. 10 to Pis.’ Appendix [89-10], hereinafter “Holbrook Dep.,” 31:13-18.) Holbrook signed a transfer order using a special “Chiefs move” to assign Santoyo to patrol; San-toyo otherwise would have been required, under the terms of the collective bargaining agreement, to return to Special Operations, where he had been assigned prior to the detail. (Pis.’ Resp. to County SOF ¶ 23; Santoyo Dep. at 70:16-71:3; Hol-brook Dep. at 31:3-33:3.) Gary Hickerson, within the Department of Corrections, signed the transfer order moving Plaintiffs Greene and Jones from the detail to then-previous positions with the Department of Corrections. (Dec. 7, 2010 Personnel Memorandum, Ex. 11 to CCSO SOF [74-11]; Pis.’ Resp. to CCSO SOF ¶ 61.) When Plaintiffs were transferred from the detail, their salaries changed accordingly; their base salaries were reduced, but they were once again eligible for overtime. (County Resp. to SAF ¶ 21; Pis.’ SAF to County ¶ 21.) III. Job responsibilities of security specialists Defendant Preckwinkle testified that her concerns about keeping Plaintiffs on the security detail stemmed from her belief that they would not be trustworthy or loyal because of the political animosity between her and Stroger. (See Dep. of Toni Preckwinkle, Ex. 11 to Pis.’ Appendix [89— 11], hereinafter “Preckwinkle Dep.,” 29:6-9 (“Loyalty and being able to keep confidences and being discreet are critical on your detail, and I had no reason to believe that any of those people [Plaintiffs] had those characteristics.”); id. at 24:13-26 (“I never believed they could be — that I could trust them ... [b]eeause they were Todd Stroger’s detail.”).) In their role as security specialists, Preckwinkle feared, the Plaintiffs would have the opportunity to overhear confidential conversations. (See County SOF ¶¶ 41, 47.) Members of the security detail receive a copy of the President’s schedule at the start of each day, and begin their day by driving the President from his or her home to the office. (Pis.’ Resp. to County SOF ¶ 38; Pis.’ Resp. to CCSO SOF ¶ 30.) During the transport, the President sits in the back of the vehicle and two security specialists sit in front. (Pis.’ SAF to County ¶ 6.) The security specialists are able to hear important and highly sensitive conversations in the car, Defendants contend. (County SOF ¶ 67; CCSO SOF ¶ 31; County Resp. to SAF ¶ 6.) Plaintiffs do not deny that this is possible, but they maintain that, while driving President Stroger, they did not listen to what was said because they were focused on driving and on scanning the road for potential threats. (Pis.’ Resp. to County SOF ¶42; Pis.’ Resp. to CCSO SOF ¶ 31.) On arrival at the County building, the security specialists ensure that the President makes it safely into the building and into his or her office. They then wait in a separate office until the President needs to travel to another location. (Pis.’ SAF to County ¶ 4-5.) While working for President Stroger, Plaintiffs assert, the security specialists did not sit in on meetings in the President’s office. (Id.) Similarly, during President Stroger’s lunch meetings, the security specialists sat at a nearby table in the same restaurant and did not overhear conversations. (Pis.’ Resp. to County SOF ¶ 39.) On weekends, members of the security detail drove President Stroger and his family as needed, including to family events. (Pis.’ Resp. to County SOF ¶ 40.) Defendants note that Greene has been inside Stroger’s home. (County SOF ¶ 40.) Given these responsibilities, Defendants characterize the security specialist position as one that requires an “intimate” relationship with the Cook County Board President. (County Defs.’ Reply Mem. in Supp. of Mot. for Summ. J. [90], hereinafter “County Reply Mem.” 4-5.) After Plaintiffs were reassigned, there' was no one immediately available to provide security for President Preckwinkle. (CCSO SOF ¶¶ 50-51.) Some of President Preckwinkle’s volunteers from the campaign filled in for a few days, and the Sheriffs Office pulled in John Palcu, from the Forest Preserve, who' had previously served on the security detail for John Stro-ger and Bobbie Steele and later became the commander of Todd Stroger’s detail. (Pis.’ Resp. to County SOF ¶ 30; Greene Dep. at 25:3-5, 29:1-19.) Thus, at least briefly, Ms. Preckwinkle brought in Plaintiffs’ own former supervisor to serve on her security detail. IV. Shakman Decree In 2010, both the County and the Sheriffs Office were bound by Shakman Consent Decrees. (Pis.’ Resp. to County SOF ¶ 79.) The Shakman case, filed in 1969, was a challenge to political patronage practices throughout Illinois state and local government. See Shakman v. Democratic Org. of Cook Cnty., 481 F.Supp. 1315, 1321 (N.D.Ill.1979) vacated sub nom. Shakman v. Dunne, 829 F.2d 1387 (7th Cir.1987). The Shakman Consent Decree broadly prohibits reliance on political considerations in employment decisions within the Sheriffs Office and within Cook County. (Id.) Certain positions are, however, exempt from Shakman Decree protections. The parties here agree that the security specialist position has never been listed on a Shakman exempt list. (County Resp. to SAF ¶ 18.) Because there was no written job description or official hiring plan for the security specialists when President Preckwinkle was searching for new members of the security detail, Brian Towne in the Sheriffs Office worked with the Shak-man compliance monitor for the Sheriffs Office to develop a job description and hiring process for the security specialist positions. (Pis.’ Resp. to County SOF ¶ 79.) ■ The final product of those efforts was a process memorialized in “Article W” to the Sheriffs Employment Action Manual (“SEAM”). (County Resp. to SAF ¶ 10.) Under Article W, the President or her designee selects a candidate for security specialist and forwards the name to the Sheriffs Office Chief of Staff and the Shakman compliance officers for the County and the Sheriffs Office. (County Resp. to SAF ¶ 13; Article W, Ex. 18 to Pis.’ Appendix [89-18], hereinafter “Article W.”) The Sheriffs Office then performs a basic background screening and delivers the results to the President or her desig-nee to issue the final written approval or disapproval of the candidate. (Article W ¶¶ C-E.) Article W specifically, and repeatedly, prohibits either the Sheriffs Office or the Cook County Board President’s Office from considering political affiliation in the hiring decision, and a designee from the County Board President’s Office and the Sheriffs Office must sign a “No Political Consideration Certificate” confirming that politics did not play a role in the hiring process. (Article W ¶¶1, II.E, III.D, IV.D; County Resp. to SAF ¶¶ 14-15.) The job description for the security specialist position was issued on December 28, 2010. (County Resp. to SAF ¶ 1.) The job description lists' the following “Key Responsibilities and Duties”: • Acts as a protective detail to an assigned Cook County elected official to ensure his/her physical safety at all times. • Drives the lead vehicle, the Cook County elected official’s vehicle or any follow-up vehicle, as required or assigned to ensure safety; follows all local and state laws in the operation of any motor vehicle. • Provides security coverage as required at the Cook County elected official’s private residence. • Reviews and assesses information relevant to the assigned protective operation to anticipate problems or incidents. • Responds to emergency situations. • Is capable of handling threats or ambush situations; recognizes situations that require notification to a ' law enforcement agency; has knowledge of procedures and protocol to maintain any evidence required in any subsequent investigation conducted by a law enforcement agency. • Serves as a member of an advanced team that plans and coordinates protective operations; conducts site surveys to assess factors affecting the protective environment of sites to be visited. • Cooperates with and assists all law enforcements agencies, as needed. (Job Description, Ex. 17 to Pis.’ Appendix [89-17], hereinafter “Job Description,” 1.) The bottom of the description also includes a notice that “[t]he Cook County Sheriffs Office prohibits all unlawful discrimination in its hiring and promotional practices.” (County Resp. to SAF ¶ 1, Job Description at 2.) Following the Article W process, Preck-winkle’s team hired Delwin Gadlen, Kelvin Pope, and Keith McLendon for the security detail in the first week of January 2011. (Pis.’ Resp. to County SOF ¶ 31; County Resp. to SAF ¶ 39.) Each of the three had volunteered as drivers and security guards for Preckwinkle during her campaign. (Pis.’ Resp. to County SOF ¶¶ 31, 76-77; County Resp. to SAF ¶ 26.) Plaintiffs filed this action on November 1, 2012, alleging that Defendants removed Plaintiffs from the security detail based on political considerations ' in violation of Plaintiffs’ First and Fourteenth Amendment rights. Plaintiffs seek compensatory and punitive damages and injunctive relief, including reinstatement to their Security Specialist title, rank, and pay rate. (Compl.[l], 6-7.) DISCUSSION Two motions for summary judgment are pending, one filed by the County Defendants and one by the Sheriffs Office Defendants. Both motions argue (1) that the security specialist position is confidential and therefore exempt from First Amendment protections, and (2) that Plaintiffs have failed to establish a prima facie case of political retaliation. County Defendants also urge that Cook County Board President Toni Preckwinkle is entitled to qualified immunity. Summary judgment is appropriate only when “the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(c); Timmons v. Gen. Motors Corp., 469 F.3d 1122, 1125 (7th Cir.2006) (citing Celotex Corp. v. Catrett, 477 U.S. 317, 322-23, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986)). In determining whether a genuine issue of material fact exists, the court views the evidence in the light most favorable to the non-moving party — here, Plaintiffs — and draws all reasonable inferences in the non-moving party’s favor. Gillis v. Litscher, 468 F.3d 488, 492 (7th Cir.2006) (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986)). The moving party has the initial burden to show that the evidence is insufficient to establish a material element of the non-moving party’s case. Celotex Corp., 477 U.S. at 322-23, 106 S.Ct. 2548. If the moving party meets this burden, the non-moving party must then “come forward with specific facts showing there is a genuine issue for trial.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). A factual dispute is genuine when “the evidence is such that a reasonable jury could return a verdict for the nonmov-ing party.” Carroll v. Lynch, 698 F.3d 561, 564 (7th Cir.2012). I. Defendants have not established that the security specialist position is a confidential position as a matter of law Defendants urge that summary judgment is appropriate because the security specialist position falls, as a matter of law, within the “confidential position” exception to the general prohibition on political patronage employment decisions. (Cnty. Defs.’ Mem. in Supp. of Mot. for-Summ. J. [78], hereinafter “County Mem.,” 3-7; CCSO Defs.’ Mem. in Supp. of Summ. J. [73], hereinafter “CCSO Mem.,” 11-12.) The First Amendment generally “forbids government officials to discharge or threaten to discharge public employees solely for not being supporters of the political party in power.” Rutan v. Republican Party of Ill., 497 U.S. 62, 64, 110 S.Ct. 2729, 111 L.Ed.2d 52 (1990). Yet, when “the nature of the public official’s job makes political loyalty a valid qualification for the effective performance” of the position, the general rule gives way. Davis v. Ockomon, 668 F.3d 473, 477 (7th Cir.2012). The Supreme Court has clarified that the test requires courts to undertake a “functional analysis” of the job -responsibilities to determine whether political loyalty “is an appropriate requirement.” Branti v. Finkel, 445 U.S. 507, 518, 100 S.Ct. 1287, 63 L.Ed.2d 574 (1980). As the Seventh Circuit has recognized, however, even after Branti, the older formal categories still have some purchase: when a position can be characterized as either “policymaking” or “confidential,” that position will likely fall within the realm of legitimate patronage. Davis v. Ockomon, 668 F.3d 473, 477 (7th Cir.2012). That test is met here, Defendants urge: Security specialists are “confidential positions,” they argue, and therefore, Defendants were entitled to consider political factors in filling those slots. “The question of whether a position is exempted from the First Amendment patronage dismissal ban is a factual one that should ordinarily be left for a jury to determine.” Pleva v. Norquist, 195 F.3d 905, 912 (7th Cir.1999). Courts may, however, resolve the question as a matter of law in two circumstances: (1) where the job functions are clearly defined by law, such as a state statute or local ordinance, see Pleva, 195 F.3d at 912; or (2) where a reliable job description provides a “safe harbor” for the defendant-employer’s reliance on political factors. Riley v. Blagojevich, 425 F.3d 357, 365 (7th Cir.2005); see also Ockomon, 668 F.3d at 478. Neither circumstance presents itself here. No party has identified a state statute or local ordinance that outlines the job functions of a security specialist, and while there is a job description in the record, it does not require the conclusion that political factors were appropriate considerations in this case. A reliable job description can serve as a safe harbor if it sets forth political affiliation as a requirement of the job. See Riley v. Blagojevich, 425 F.3d 357, 364 (2005). But if the job description is “unclear whether the job confers any policy-making or confidential discretion, then additional evidence would be necessary.” Id. at 365. The language of the security specialist job description does not support Defendants’ position that the security specialists exercise confidential discretion. Defendants note that the job description includes the following functions: • ensure that the elected official is able to carry out Cook County policy ... • ensure [the public official’s] physical safety at all times ... • provide security coverage as required, at the Cook County elected official’s private residence ... • serve[ ] as a member of an advanced team that plans and coordinates protective operations; conduct[ ] site surveys to assess factors affecting the protective environment of the sites to be visited. (Job Description; County Reply Mem. at 5.) Yet, as Plaintiffs note, this language includes neither “political loyalty” nor even “confidentiality” or “discretion” within the job description. Defendants argue that the broad statement that a security specialist ensures “that the elected official is able to carry out Cook County policy” means political considerations are appropriate. This broad statement does not recognize policy discretion in the security specialists themselves, however, and Defendants have not explained how the sentence otherwise reveals that “confidential discretion” is an important job function. Indeed, Defendants’ proposed reading of the job description appears to be inconsistent with “Article W,” developed in the very month when Plaintiffs were reassigned, which dictates the hiring process for security specialists. That Article states that “political reasons or factors ... may not be considered in making selections for these positions.” (Article W at § I.) Although Article W also permits a security specialist to “be transferred at the discretion of the President/designee or the CCSO Chief of Staff,” it imposes the requirement that any manager involved in the decision sign a certificate “verifying that Political Reasons or Factors were not considered in the transfer.” (Article W. at §§ III.A, III.D.) These documents— which are at best unclear, and at worst explicitly prohibit the consideration of political affiliations — do not create a safe harbor which entitles Defendants to summary judgment as a matter of law. Notably, even if the job description is read to support Defendants’ position here, it would not be dispositive; the job description was not created until December 30, 2010, three weeks after the Plaintiffs were removed from their positions on the detail. A job description written in late December might codify existing practice; but to the extent it appears helpful to Defendants, it may be understood as a post-hoc effort to justify reliance on political considerations. Viewed in the light most favorable to Plaintiffs, the job description does not defeat their claims. County Defendants respond to these concerns about the job description by noting that “both former President Stroger and President Preckwinkle testified that loyalty and trustworthiness are vital for this position.” (County Reply Mem. at 2-3.) As Defendants emphasize, security specialists are able to overhear conversations in the car, they have access to the President’s schedule, and they interact with the President’s family. (County Mem. at 3-5.) Plaintiffs, who performed the security specialist duties for President Stroger, insist the security specialists do not overhear significant amounts of confidential information. It is possible for them to do so, Plaintiffs acknowledge, but they contend that their attention is focused on the road, and not the conversation. (Pis.’ Resp. to County SOF ¶42; Pis.’ Resp. to CCSO SOF ¶ 31.) They note, as well, that while the President conducts business in his or her office in the County Building, the security specialists sit in a separate office. (Pis.’ SAF to County ¶ 4-5.) And, when the County Board President meets someone for lunch, Plaintiffs assert, the security specialists sit at a separate table and do not listen to the communications. (Pis.’ Resp. to County SOF ¶ 39.) There are, in short, factual disputes regarding the job functions of security specialists and whether political loyalty is an appropriate consideration. Resolving these factual disputes would require weighing evidence, which is inappropriate at this stage of the litigation. Washington v. Haupert, 481 F.3d 543, 550 (7th Cir.2007). Regardless of the specific job functions, Defendants argue, the unique combination of an intimate working relationship and strong political hostility requires summary judgment in their favor. They rely on Meeks v. Grimes, 779 F.2d 417 (7th Cir.1985). In Meeks, former bailiffs of the Gary City Court, who were appointed by the judge they served, lost their jobs after the judge lost a contentious primary that “generated considerable ill will.” 779 F.2d at 418. After a bench trial, the District Court concluded that although the firings were political, they were exempt from First Amendment protection because the bailiffs were confidential employees. Id. at 418. On appeal, the Seventh Circuit acknowledged that: political antipathy can serve as a decent proxy for a lack of trust and loyalty where the employee’s responsibilities include a duty to shield the decisionmak-ing process from the outside world. The possibility of ‘leaks’ from employees with access to the sensitive information is a constant threat to any unit of government. Id. at 420. Seizing on this language, Defendants contend that because security specialists necessarily overhear at least some confidential information, President Preckwinkle was not obligated to keep Todd Stroger’s political allies to provide security in private settings. (County Reply Mem. at 4-5.) The quoted language from Meek's may provide support for Defendants’ argument here, but its holding does not. The Seventh Circuit reversed the District Court’s conclusion that the bailiffs were confidential. employees, rejecting the argument that “access to court records when coupled with political animosity creates a serious threat of politically motivated breaches.” Meeks, 779 F.2d at 421. The court noted that the bailiffs “are duty-bound” to keep the information confidential, “and, while political affiliation may be an acceptable proxy for loyalty [and] trust, ... it would cast the net of the [confidentiality] exception too wide to allow political support to be used to extrapolate a tendency to breach a sworn duty, behave unprofessionally, or commit criminal acts.” Id. Political animosity, even when coupled with access to confidential information, thus does not necessarily create an exception to patronage protections. There are, the court recognized, “circumstances in which the animosity engendered by a political struggle makes it impossible for two people to work together in an intimate environment,” id. but those cases are rare: unless the employer shows that the political animosity would “invariably lead to a[n] untenable work situation,” then political considerations are constitutionally impermissible. Id. Since Meeks, the majority of cases considering exceptions to the prohibition on political patronage address positions where plaintiffs exercised discretion over implementation of government policy. See e.g., Embry v. City of Calumet City, 701 F.3d 231, 236 (7th Cir.2012) (Commissioner for Streets and Alleys of Calumet City is a policymaking position because the Commissioner oversees construction and repair of City’s public ways and manages department’s forty employees and four-million dollar budget); Davis v. Ockomon, 668 F.3d 473, 479 (7th Cir.2012) (Senior Humane Officer for the City of Anderson, Indiana exercises policy discretion because the Officer is responsible for implementing and enforcing animal control statutes and regulations, including determining when to revoke licenses and permits); Fuerst v. Clarke, 454 F.3d 770, 773 (7th Cir.2006) (sergeants in Milwaukee County Sheriffs Department are not policymaking officials because they exercise only modest supervisory authority over “the cops on the beat” and do not formulate departmental policy); Riley v. Blagojevich, 425 F.3d 357, 363-64 (7th Cir.2005) (Assistant Wardens of Illinois state prisons exercise policymaking authority because they routinely stand in for the top prison official and make policy judgments for individual prisons); Thompson v. Illinois Dep’t of Prof'l Regulation, 300 F.3d 750, 757 (7th Cir.2002) (Chief ALJ of the Illinois Department of Professional Regulations is a policymaking position because the combination of responsibilities includes “directing subordinate staff, formulating procedures for the hearing programs, advising peer review committees, developing hearing program goals, and directing and implementing the program budget”; those duties show that the Chief ALJ “spends a considerable amount of time formulating policy and implementing broad goals.”). There is relatively little guidance on cases like this one, where the position involves no policymaking responsibilities, but the job functions nonetheless include close personal contact with a chief executive and opportunities to overhear private conversations of a political official. The handful of cases that do address such positions reveals that whether political affiliation is an- appropriate consideration for a particular position is highly fact-specific. In Matlock v. Barnes, the plaintiff James Matlock was a legal investigator for the City of Gary’s Law Department, where he investigated accidents and small property damage claims by taking statements from witnesses, taking photographs, and obtaining relevant medical and administrative records. 932 F.2d 658, 660 (7th Cir.1991). Matlock was transferred to the Gary City Jail after a new mayor, whom Matlock had campaigned against, took office. Id. at 661. Matlock sued, arguing that his transfer was improperly based on political considerations. Id. On appeal from a verdict in Matlock’s favor, defendants urged that the legal investigator position was a confidential position as a matter of law because Matlock “had access to all court files, [and defendants] lost confidence in Matlock’s ability to safeguard the secrecy of the office upon seeing how close Matlock was” to the former mayor. Id. at 664. The Seventh Circuit was not persuaded. The court noted that “defendants could have established the confidentiality of Matlock’s position by offering convincing proof of their unease about working in small quarters in direct and constant contact with Matlock,” but the jury simply did not believe “defendants’ professed concern.” Id. at 665. Next, in Carlson v. Górecki, the Seventh Circuit again considered investigators: plaintiffs, who served as special investigators for the Kane County, State’s Attorney’s office, were responsible for locating and interviewing witnesses, serving subpoenas, and transporting witnesses to court. 374 F.3d 461, 465 (7th Cir.2004). The Seventh Circuit noted that “[a]ccess to confidential files by a lower-level employee who, while not a policymaker, is openly politically hostile, may be reason for termination,” id. at 466, but concluded that the evidence was insufficient to establish as a matter of law that party affiliation was an appropriate requirement for the special investigator positions. Id. The court therefore affirmed the district court’s determination that the defendant was not entitled to qualified immunity from suit. Most recently, in Benedix v. Village of Hanover Park, Illinois, the Seventh Cir-euit considered the position of the Executive Coordinator of the Village of Hanover Park, which a new Village administration eliminated through an ordinance. 677 F.3d 317, 318 (7th Cir.2012). The District Court granted defendants’ motion to dismiss based on legislative immunity and plaintiff appealed, arguing that that the Village is not entitled to such immunity. Id. Bypassing that issue, the Seventh Circuit affirmed the dismissal on the ground that the Executive Coordinator position was a “confidential one.” Id. at 320. According to the plaintiffs brief, the Executive Coordinator “reported directly to and worked closely with” the Village manager. Id. Accepting plaintiffs assertion that the position was not a policymaking role, and relying solely on plaintiffs own minimal description of her job functions, the Seventh Circuit concluded that the “a position as a policymaker’s right-hand woman must be deemed a ‘confidential’ one.” Id. at 320. This case resembles Matlock and Carlson, where plaintiffs have some access to confidential information but are viewed by the new administration as political enemies. In those cases, the Seventh Circuit acknowledged that such a combination might, in fact, create an untenable working situation, but observed that the combination of access to confidential information and political hostility alone does not transform a position into a “confidential” position as a matter of law. President Preck-winkle may have genuinely believed that keeping Plaintiffs on the detail would have created precisely such an untenable work situation. But under the approach outlined by Meeks, Matlock, and Carlson, whether President Preckwinkle’s belief was genuine or accurate, is for the jury to decide. The facts surrounding this issue are heavily disputed. First, the parties disagree over how close Todd Stroger was to Plaintiffs, and therefore how much political animosity would have existed between Plaintiffs and President Preekwinkle. Defendants note that Greene and Jones volunteered one day a week during Stroger’s campaign and were therefore political appointees. (Pis.’ Resp. to CCSO SOF ¶ 12.) They also characterize Stroger and Greene as long-time friends from the same neighborhood {see County SOF ¶ 9), but Greene’s testimony describes a more distant relationship. {See Greene Dep. at 25:16-24) (“I knew about him, and he knew about me ... but it wasn’t a personal relationship.”) Furthermore, Santoyo appears to have -no connection to Stroger other than working on his detail. Therefore, whether Plaintiffs can be fairly characterized as political enemies — and what information was available to President Preekwinkle about that issue — are open questions. Second, Plaintiffs have presented evidence that even if there was political animosity, it would not have interfered with Plaintiffs’ job performance. For example, Santoyo testified that he understood his job was “to protect the County board president, whoever that — no matter who it was.” (Santoyo Dep. at 33:16-18.) Phil Stephens, the former director of the detail under Todd Stroger from 2007 to 2010 (County SOF ¶ 6), testified more colorfully: “Our responsibility is, we don’t care who is president, democrat, republican, martian, you know, Satan himself, whoever; our job is, we work for the office of the president.” (Dep. of Philip Stephens, Ex. 6 to Pis.’ Appendix [89-6], hereinafter “Stephens Dep.,” 59:24-60:3.) John Palcu, the director of the detail before Stephens, explained that the Plaintiffs “were professional enough to serve whoever was in the office. They know their duties.” (Dep. of John Palcu, Ex. 7 to Pis.’ Appendix [89-7], hereinafter “Palcu Dep.,” 32: 12-14.) On this record, there are genuine questions of fact regarding the level of political animosity between Plaintiffs and Defendant Preckwinkle and whether any political animosity that did exist would have-interfered with the Plaintiffs’ job performance. Plaintiffs have presented some evidence that their political views would not interfere with their effective performance of the security specialist position. Defendants have not identified any state law, local ordinance, or job description that requires the conclusion that political loyalty — or even confidential discretion — is an appropriate qualification for the position. Defendants, therefore, have not met their burden of showing that the security specialist position is a confidential position as a matter of law. II. Prima facie case Next, Defendants argue that Plaintiffs have failed to establish a prima facie case that they lost their positions as security specialists for political reasons. The Seventh Circuit has repeatedly identified the specific elements a public employee must show to establish that an employment decision rested improperly on political considerations. See Kidwell v. Eisenhauer, 679 F.3d 957, 964-65 (7th Cir.2012); Zerante v. DeLuca, 555 F.3d 582, 584-85 (7th Cir.2009). Specifically, a nonexempt employee can establish a violation by demonstrating (1) that his conduct was constitutionally protected; (2) that he suffered an actionable deprivation; and (3) that the protected conduct was a motivating factor for the adverse employment action. See Kidwell, 679 F.3d at 964-65. Sheriffs Office Defendants assert that Plaintiffs have failed to establish any of the three elements of a First Amendment violation. They note that summary judgment is proper “against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.” Celotex Corp., 477 U.S. at 322, 106 S.Ct. 2548. The court disagrees and concludes that Plaintiffs have presented evidence sufficient to support each element. A. Protected Conduct Plaintiffs have characterized their protected conduct as non-affiliation with Toni Preckwinkle. “It is undisputed that political nonaffiliation is a right protected under the first amendment.” Hermes v. Hein, 742 F.2d 350, 354 n. 3 (7th Cir.1984) (citing Elrod v. Burns, 427 U.S. 347, 350, 96 S.Ct. 2673, 49 L.Ed.2d 547 (1976)). Sheriffs Office Defendants counter that “Plaintiffs have presented no evidence of their claimed apolitical status that distinguishes them from numerous other County employees who do not participate in campaign activities.” (CCSO Mem. at 7) (citing Zerante v. DeLuca, 555 F.3d 582, 585 (7th Cir.2009).) First; the court notes that Defendants’ argument addresses causation rather than whether the Plaintiffs’ non-affiliation is protected conduct. Plaintiffs’ non-affiliation with President Preckwinkle remains protected conduct regardless of whether other County employees were similarly non-affiliated. In any event, ample evidence supports the conclusion that Plaintiffs were removed from the security specialist detail because of their perceived affiliation with Todd Stroger, President Preckwinkle’s political opponent. President Preckwinkle herself explained that she “never believed they could be — that I could trust them ... because they were Todd Stroger’s detail.” (Preckwinkle Dep. at 25:13-16.) She confirmed, further, that she understood Todd Stroger’s “detail to be associated with him[.]” (Preckwinkle Dep. at 25:17-19.) President Preckwinkle’s distrust was not confined to the Todd Stroger security detail; she testified that “I didn’t trust the overwhelming majority of the people that Todd brought in.” (Preckwinkle Dep. at 28:11-13.) Therefore, even if Defendants are correct that Plaintiffs cannot be distinguished from other members of Stroger’s administration, that assertion does not defeat the inference that their political affiliation (or non-affiliation with President Preckwinkle) motivated the decision challenged here. B. Actual Deprivation Next, the Sheriffs Office Defendants argue that Plaintiffs did not suffer an actionable deprivation because their transfers resulted in no loss of rank, merit, or prestige. (CCSO Mem. at 7.) To show an adverse employment action, Plaintiffs need to present evidence of “some quantitative or qualitative change in the terms or conditions of his employment or some sort of real harm.” Atanus v. Perry, 520 F.3d 662, 675 (7th Cir.2008) (internal quotation marks and citation omitted). As the Sheriffs Office Defendants themselves acknowledge, Plaintiffs received higher salaries when they were transferred to the detail. {See CCSO SOF ¶¶ 37-38) (“The security specialist assignment was considered a detail for which the individuals were paid a higher a higher rate of pay because they worked long and unexpected hours including weekends but did not receive overtime pay.”) A reduction in that higher pay rate or a loss of benefits plainly constitutes adverse employment action. See Harper v. Fulton Cnty., Ill., 748 F.3d 761, 767 n. 5 (7th Cir.2014). There may be questions regarding Plaintiffs’ overall pay 0ie., whether the higher salaries and additional work, coupled with ineligibility for overtime pay, actually resulted in greater overall net income), but those disputes are not properly resolved at summary judgment. Moreover, apart from any pay differential, Plaintiffs’ transfers may still be actionable if their transfers resulted in a loss of prestige. “The First Amendment requires a deprivation ‘likely’ to deter free speech, a standard considered more lenient than the Title VII counterpart of adverse action.” Hobgood v. Illinois Gaming Bd., 731 F.3d 635, 643 (7th Cir.2013). Plaintiffs assert that they each “received a promotion” when they were assigned to the detail and that their transfers were “demotions.” (Pis.’ SAF to CCSO ¶ 21.) Luis Santoyo testified that he was promoted when he was assigned to the detail and demoted when he was transferred back to patrol. (Santoyo Dep. at 85:14-20.) Rosemarie Nolan, the Director of Personnel for the Sheriffs Office similarly characterized the transfers to the security detail as promotions and the transfers from the detail as demotions. (Dep. of Rosemarie Nolan, Ex. 5 to Pis.’ Appendix [89-5], hereinafter “Nolan Dep.,” 48:3-12, 49:15-16.) The County Defendants have admitted that Plaintiffs received promotions and raises when they were transferred to the detail and corresponding demotions when they were transferred from it. (County Resp. to SAF ¶21.) This evidence supports an inference that the security detail assignment was a higher-rank or higher-prestige position, the loss of which is likely to deter free speech. Plaintiffs have, accordingly, presented sufficient evidence of an actual deprivation for purposes of summary judgment. C. Causation The Sherriff s Office and Defendant Holbrook urge the court to grant summary judgment in their favor because Plaintiffs have not satisfied the third element of an unconstitutional political patronage claim: causation. (CCSO Mem. at 7-8.) The Sheriffs Office Defendants assert that the appropriate standard is whether the political consideration was the “but-for” cause of Plaintiffs’ transfers. They maintain that no one in the Sheriffs Office was aware that political factors were at play in the decision to remove Plaintiffs from the detail. (Id.) Alternatively, they argue that even if someone in the Sheriffs Office was aware of the political motivations, Plaintiffs cannot establish but-for causation because the Sheriffs Office’s actions were motivated, not by Plaintiffs’ political affiliations, but by an attempt to “end the detail altogether,” that is, an attempt by the Sheriffs Office to get “out of the security detail business” by shifting the detail to the President’s Office budget so that the Sheriffs Office no longer had any authority over the detail. (CCSO Reply Brief in Supp. of Summ. J. [93], hereinafter “CCSO Reply Mem.,” 6; CCSO Mem. at 9.) At the outset, the court notes that the Sheriffs Office Defendants misstate the causation requirement. Plaintiffs are not required to show but-for causation at this stage of litigation. Rather, to survive summary judgment, they need establish only that political considerations were a motivating factor. The Sheriffs Office Defendants are correct that, to succeed at trial Plaintiffs will have to establish but-for causation, but at this stage “to establish a prima facie case ... the plaintiff must produce evidence that his speech was at least a motivating factor ... of the employer’s decision.” Kidwell v. Eisenhauer, 679 F.3d 957, 965 (2012). If the plaintiff offers evidence that the protected conduct was a motivating factor, the burden shifts to the employer; if the employer cannot rebut the causal inference, the plaintiff has established the necessary but-for causation. Id. Thus, at summary judgment, Plaintiffs are required to show only that their protected conduct “was at least a motivating factor” in Defendants’ employment decision. Id. See also Massey v. Johnson, 457 F.3d 711, 717 (7th Cir.2006) (explaining that motivating factor is a lower hurdle than but-for causation). The Sheriffs Office Defendants try to distance themselves from the actions of the President’s Office and argue that because they are a separate entity from the President’s Office, the Plaintiffs cannot prove any set of facts that implicates the Sheriffs Office in the decision to transfer Plaintiffs from the detail. (CCSO Reply Mem. at 5-6.) The Sheriffs Office Defendants maintain that it was the President’s Office that initiated the decision to remove Plaintiffs from the detail. They do not dispute, however, that the Sheriffs Office took the administrative actions required to transfer Plaintiffs, and they admit that the Sheriffs Office had the authority to — and did in fact — transfer Plaintiffs to other positions. (See CCSO SOF ¶¶46, 49.) They further admit that Defendant Hol-brook signed the transfer order terminating Santoyo’s position in the detail and transferring him, using the “Chiefs move,” back to patrol. (CCSO Resp. to SAF ¶ 39; Personnel Memorandum 10-59, Ex. 25 to Pis.’ Appendix [89-25].) Instead, the Sheriffs Office disputes the motivations it had for making the transfers. According to the Sheriffs Office, it had no choice: it was simply responding administratively to the President’s Office’s independent decision to end the existing security detail and transfer the detail to its own budget. (See CCSO Reply Mem. at 6.) Defendant Holbrook similarly argues that signing the transfer order was nothing more than a “ministerial task” that occurred after President’s Office made the final decision to end the existing detail. (CCSO Mem. at 11.) Both the Sheriffs Office and Defendant Holbrook maintain that once the President’s Office articulated that it wanted to replace the detail, the detail ended, and the Sheriffs Office Defendants cannot be liable for responding to the President’s Office’s decision. A jury may agree with the Sheriffs Office Defendants, but their assertions are not the only way to interpret the facts. First, the fact that the security detail was never actually transferred to the President’s budget undermines the Sheriffs Office theory that they were simply “ending the detail in its entirety.” Additionally, County Defendants have presented evidence, not only that the Sheriffs Office knew about the political motivations, but that Brian Towne, the Chief of Staff to the Sheriff, caused Plaintiffs to be transferred. John Keller testified that it was Towne who initially suggested replacing Plaintiffs, by asking whether President Preckwinkle wanted to remove Stroger’s team. (County SOF ¶ 72.) Towne then directed Rosemarie Nolan to transfer the Plaintiffs to different positions within the Sheriffs Office. (Pis.’ Resp. to CCSO SOF ¶ 49.) From these facts, a reasonable jury could conclude that Brian Towne offered to remove individuals associated with Todd Stroger and that the Cook County Sheriffs Office, through Towne, actually caused the Plaintiffs’ transfers. A motivating factor may be proved by either direct or circumstantial evidence. Kidwell, 679 F.3d at 965. Circumstantial evidence may include suspicious timing, ambiguous oral or written statements, or behavior towards or comments directed at other employees in the protected group. Long v. Teachers’ Retirement Sys. of Ill., 585 F.3d 344, 350 (7th Cir.2009). A jury might infer based on Keller’s testimony, the timing of the Plaintiffs’ transfers, and Brian Towne’s instructions to Rosemarie Nolan to end the detail, that Brian Towne initiated and directly caused the transfers. Another reading of the facts supports the conclusion that the Sheriffs Office and Defendant Holbrook, even if they did not initiate the transfers, knew about President Preckwinkle’s politically motivated decision to remove Plaintiffs and ratified or condoned that decision by effectuating the transfers. The Sheriffs Office admits that Brian Towne knew, from his conversation with John Keller, that President Preckwinkle wanted to remove anyone affiliated with Stroger from the detail. The Sheriffs Office also maintains that Towne ended the detail in response to Keller’s request. (CCSO SOF ¶ 48) (“If Keller had not advised the Sheriffs Office that the President’s Office intended to bring on their own people for the security detail, the Sheriffs Office would not have changed the members of the detail.”) A reasonable jury could accept the Sheriffs Office’s position that it was simply trying to “get out of the security detail business,” (CCSO Reply Mem. at 6), but nevertheless infer that Brian Towne understood that President Preckwinkle’s motivation for “ending the detail” was to permit President Preckwinkle to remove Plaintiffs from their positions because of their affiliation with Todd Stroger. This conclusion is bolstered by the fact that Towne apparently communicated President Preckwin-kle’s political considerations to other employees in the Sheriffs Office in order to explain why the detail was ending. For example, according to Santoyo, Defendant DeWayne Holbrook told him that the detail was ending because President Preck-winkle’s administration had “their own people.” (County Resp. to SAF ¶ 23.) Bill Evans, then the Police Commander, also testified that Holbrook told him that “the board president w