Source: cases/29usc623/f-supp-3d-380-783-spratt-v-bellwood.case
Case source: https://www.neochart.com/catalog/cases/f-supp-3d/volume_380/0783_01/index.html
Spratt's Amended Complaint sufficiently alleges each element of a retaliation claim under the ADEA.
An action is materially adverse if it might have 'dissuaded a reasonable worker from making or supporting a charge of discrimination.'
Moreover, Spratt's allegations that she was placed on administrative leave and endured months of adverse workplace conduct following her EEOC charge is sufficient to deter a reasonable employee from engaging in future protected activity.
The Court finds that these allegations sufficiently allege a causal link.
casedsl 1 case /f-supp-3d/380/0783-01 name Spratt v. Bellwood Public Library cite 380 F. Supp. 3d 783 (2019) court United States District Court for the Northern District of Illinois date 2019-05-21 url catalog/cases/f-supp-3d/volume_380/0783_01/index.html source ir/caselaw/f_supp_3d_380.jsonl sha1=601b56efebdd2bdb35830bf9281e42580454953f chars=17902 law 29usc623 role applied posture Rule 12(b)(6) motion to dismiss retaliation claim result claimant-won element protected-activity : satisfied [pleaded] role applied scope merits variant participation/eeoc-age-discrimination-charge fact @6455..6535 [supports] | Spratt alleges that Bellwood retaliated against her for filing an EEOC complaint held @7368..7467 | Spratt's Amended Complaint sufficiently alleges each element of a retaliation claim under the ADEA. gloss The pleaded retaliation allegation survived the motion to dismiss posture. element retaliatory-adversity : satisfied [pleaded] role applied scope merits variant retaliation/leave-and-termination-after-charge fact @7611..7875 [supports] | Next, she alleges that she suffered a series of adverse employment actions, including putting her on administrative leave, taking legal action against her, changing the educational requirements for her position, constructively discharging her, and terminating her. rule @7877..8011 | An action is materially adverse if it might have 'dissuaded a reasonable worker from making or supporting a charge of discrimination.' held @8472..8709 | Moreover, Spratt's allegations that she was placed on administrative leave and endured months of adverse workplace conduct following her EEOC charge is sufficient to deter a reasonable employee from engaging in future protected activity. gloss The court accepted the pleaded leave, constructive discharge, and termination as materially adverse at Rule 12(b)(6). element retaliation-causation : satisfied [pleaded] role applied scope merits variant causation/charge-followed-by-continuing-pattern fact @8819..9067 [supports] | She alleges that within two weeks of receiving her EEOC charge, Bellwood began engaging in a pattern of retaliatory conduct over nine months intended to harass her and cause her emotional distress that culminated in Spratt's constructive discharge. held @9213..9286 | The Court finds that these allegations sufficiently allege a causal link. gloss Temporal proximity and the alleged nine-month retaliatory course adequately pleaded causation. misfit Pleading sufficiency accepts allegations as true; it does not establish that the alleged retaliatory conduct occurred or that the plaintiff will prevail at trial.