Free
of Charge

The Cook County Sheriff's Office responded to FOIA R091132-041326 today with two documents. The first is a Memorandum of Understanding between the Cook County Sheriff's Office and the Chicago Transit Authority establishing a pilot program for law enforcement on the CTA transit system. The second is an arrest summary from that program. Together they answer a question this investigation has been asking since April 18: why did the CTA terminate the Monterrey contract three weeks after renewing it?

The answer, in the language of the MOU itself, is Section VII.

The CTA did not run out of money for security. The CTA arranged free security coverage and then terminated the contract it was paying for.

The Sequence

What the documents now establish

The non-appropriation of funds rationale requires the reader to believe the CTA exhausted its security budget while simultaneously operating a zero-cost law enforcement program covering the same transit system. The MOU does not explain why Monterrey was renewed on March 28 — one day after the free replacement was already operational. Those records are pending production under the board communications FOIA filed May 4, 2026, amended May 8 to include Kevin Ryan as a named custodian.

What the Arrest Data Shows

Sheriff task force activity March 27 through April 30, 2026

The CCSO also produced arrest statistics covering the task force's first 35 days. The data does not support fare enforcement as the program's primary function.

Of 98 total arrests since March 27, 16 were for fare evasion or theft of services. Outstanding warrants account for 32 arrests — the single largest category. The Sheriff task force is primarily a general law enforcement operation on CTA property, not a fare enforcement program.

This is relevant because the private security contracts this investigation has documented — $97 million for Monterrey and Inter-Con, $144.6 million for Action K-9, $430 million in combined enforcement spending including CPD — were justified publicly as fare enforcement and rider safety investments. The zero-cost replacement is doing something different and producing different outcomes, on the same transit system, at no charge to the CTA.

Who Signed What

The named parties across the document record

The MOU notices section identifies Kevin Ryan, CTA Vice President of Security, at kryan@transitchicago.com, as the named representative for the Sheriff pilot program. Kevin Ryan also signed the Monterrey termination letter. The MOU was executed by Nora Leerhsen, CTA Acting President, on March 16, 2026 — twelve days before the Monterrey contract was renewed.

The acting president of the CTA signed a zero-cost replacement security arrangement on March 16. Twelve days later, someone renewed the contract the replacement was designed to supersede. The board communications FOIA filed May 4 and amended May 8 to include Kevin Ryan seeks the records that would explain that sequence. Those records are due May 11.

A FOIA request has been filed today seeking all biweekly summaries produced by the Sheriff under the MOU, all communications between CTA and CCSO regarding the pilot program, and any internal CTA communications referencing both the Sheriff program and the Monterrey contract. The CTA's main FOIA production is due May 11.

The investigation is ongoing.

Michael Russo is the founder of PolicyTorque LLC. He is an independent policy researcher and journalist. He has no financial interest in any entity named in this investigation. Primary source documents including the Cook County Sheriff MOU, arrest statistics, CTA board ordinances, Department of Finance collection records, Department of Administrative Hearings adjudication data, FTA Special Directive, and Office of Budget and Management appropriations records are available upon request. Contact: michael@policytorque.com · 248-930-0117