In Moy v. County of Cook, 159 Ill.2d 519, 640 N.E.2d 926, 203 Ill. Dec. 776 (1994), our Supreme Court reasoned that government officers who are not removable by their parent governmental bodies are not employees whose conduct is subject to the control of their governmental employer and therefore the parent body may not be held derivatively responsible for their wrongdoing. Under Moy and under its traditional common law reasoning, it matters not whether the sheriff and his deputies are considered to be servants or agents or any other subordinate relationship to the State. In Moy, our Supreme Court held that respondeat superior does not apply officers of governmental bodies who are non-removable, as distinguished from mere employees. Moy reasoned that officers who are not removable and do not serve at the pleasure of their governmental bodies (which is true of virtually all, if not all, Illinois elected officials) are not employees subject to the control of their governmental employer and for whose improprieties the parent body is therefore responsible and may be held derivatively liable.