Sandra Kolalou, now known as Sandra White following a change in marital status, remains at the center of one of the most legally complex and publicly controversial civil compensation cases in recent Illinois history. Despite being convicted in 2024 of the murder and dismemberment of her landlord, a crime that shocked Chicago and drew national attention, Kolalou has secured a $2.8 million civil award from the Chicago Transit Authority for injuries she sustained years earlier in an unrelated bus accident.
The Illinois Appellate Court’s decision to uphold the award has reignited debate around the separation of civil liability from criminal conduct, the scope of damages in personal injury cases, and the limits of judicial discretion when later criminal convictions intersect with earlier civil claims. The case illustrates how the American legal system treats civil injury claims as distinct from a plaintiff’s later criminal actions, even when those actions are extreme.
At its core, the ruling reaffirmed the principle that compensation for negligence is tied to the facts and consequences of the incident itself, not the moral character or subsequent behavior of the injured party. For the CTA, the decision represents a costly legal outcome in a case that began more than seven years ago. For the courts, it stands as a reaffirmation of long-established doctrines governing civil damages.
The 2018 CTA Bus Accident and Civil Lawsuit
The origins of the case trace back to March 1, 2018, when Sandra Kolalou was struck by a Chicago Transit Authority bus while walking in a marked crosswalk in Chicago. The bus was driven by CTA employee Tyrone Bynum. Court records indicate that Kolalou suffered multiple injuries as a result of the collision, including orthopedic and neurological damage. She later reported chronic pain in her back and legs, along with long-term mobility issues that affected her ability to work and engage in everyday activities.
In February 2019, Kolalou filed a civil lawsuit against the CTA and Bynum, alleging negligence and seeking compensation for medical expenses, pain and suffering, loss of normal life, and future medical care. As the case progressed, both Bynum and the CTA admitted negligence, effectively narrowing the legal dispute to a single question: how much compensation Kolalou was entitled to receive for her injuries. With liability no longer in dispute, the matter went before a Cook County jury to determine damages.
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In February 2023, after reviewing medical testimony, expert evaluations, and evidence of long-term impairment, the jury awarded Kolalou $3 million. The verdict included significant sums for future medical care and future loss of a normal life, reflecting the jury’s assessment that her injuries would have lasting consequences. The CTA challenged the verdict, arguing that some of the damages were speculative, particularly those tied to future care and quality of life.
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A judge granted a new trial later that year, citing concerns over the award’s scope. During the second trial, a new jury reduced the total compensation slightly, awarding Kolalou $2.8 million. This revised verdict included $400,000 earmarked for future medical treatment and $500,000 for future loss of normal life, with the remainder covering past and ongoing damages. Even after the reduced award, the CTA continued to contest the outcome, setting the stage for the appeals process that would later draw widespread attention.
Murder Conviction and Public Outcry Over the Award
While the civil case was unfolding, Kolalou became the subject of a separate and far more serious criminal investigation. In October 2022, prosecutors say she killed her landlord, 69-year-old Frances Walker, after receiving an eviction notice. According to court filings and trial testimony, Walker’s dismembered remains were later found in a freezer at her home on Chicago’s Northwest Side, with her head, arms, and legs severed and concealed.
Kolalou was arrested after a series of events that further intensified public scrutiny. Prosecutors stated that she hired a tow truck driver to take her to a beach along Chicago’s lakefront, where she attempted to dispose of a heavy bag in a garbage can. When the driver refused to transport her to another location, she allegedly pulled a knife on him. This encounter led to police involvement and ultimately to the discovery of Walker’s remains.

In April 2024, Kolalou was convicted of first-degree murder, concealing a homicidal death, and other related charges. She was sentenced in July 2024 to 58 years in prison, a term that effectively ensures she will spend the rest of her life incarcerated. The brutality of the crime and the details presented at trial generated intense media coverage and public outrage.
Against this backdrop, news that Kolalou would still receive millions of dollars from a public transit agency sparked widespread criticism. Many questioned how someone convicted of such a crime could benefit financially from a civil award, particularly one funded by a taxpayer-supported entity. For the CTA, the conviction became a central argument in its appeal, as the agency sought to overturn or reduce the damages based on Kolalou’s incarceration and criminal status.
The CTA argued that Kolalou’s imprisonment made future medical treatment unlikely and rendered the jury’s projections of future care and loss of normal life speculative. It also contended that the civil proceedings should have been delayed or reconsidered while her criminal case was pending, suggesting that the later conviction fundamentally altered the context in which damages should be assessed. These arguments resonated with segments of the public but faced a more challenging reception in the appellate courts, where legal standards rather than public sentiment govern decision-making.
Illinois Appellate Court Ruling and Legal Implications
The Illinois Appellate Court ultimately rejected the CTA’s arguments and upheld the $2.8 million award, reaffirming the lower court’s judgment. In its ruling, the appellate court emphasized that civil liability and damages must be evaluated based on the circumstances existing at the time of the injury, not on events that occur years later.
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The court found that Kolalou’s incarceration and subsequent criminal conviction were not relevant to determining compensation for injuries she suffered in 2018. At that time, she was a private citizen with no criminal conviction related to the later murder case. The court noted that allowing a defendant to reduce or avoid civil liability based on a plaintiff’s later misconduct would undermine the predictability and fairness of civil law.

Addressing the CTA’s claim that future damages were speculative due to Kolalou’s imprisonment, the court held that the jury had been presented with sufficient medical evidence to support its findings. The fact that her circumstances later changed did not retroactively invalidate the jury’s assessment. The court also rejected the argument that the civil case should have been paused pending the outcome of the criminal prosecution, stating that there is no legal requirement to delay civil proceedings under such circumstances.
Legal analysts have pointed out that the decision aligns with long-standing principles in tort law. Civil damages are intended to compensate for harm caused by negligence, not to reward or punish moral behavior. Courts have consistently held that even individuals with criminal records or those who later commit crimes are entitled to seek compensation for injuries caused by others’ negligence.
The ruling also underscores the limited scope of appellate review in civil cases. Appeals courts generally defer to jury findings on damages unless there is clear evidence of error, bias, or a lack of evidentiary support. In this case, the appellate court found none of those conditions met. For the CTA, the decision means it must now pay the awarded damages, bringing an end to a prolonged legal battle. For the broader legal community, the case serves as a reminder of the strict boundaries courts maintain between civil compensation and criminal punishment.
While the outcome continues to provoke strong reactions, particularly given the severity of Kolalou’s crimes, the appellate ruling reinforces a fundamental aspect of the justice system: that civil rights and remedies are not extinguished by later criminal acts, and that liability for negligence is determined by facts, evidence, and law, rather than by the subsequent actions or character of the injured party.
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