Spratt v. Bellwood Public Library

380 F. Supp. 3d 783 (2019) United States District Court for the Northern District of Illinois 2019-05-21

Rule 12(b)(6) motion to dismiss retaliation claim (result: claimant-won)

Facts

  1. 9 Opposition or participation satisfied pleaded
    Spratt alleges that Bellwood retaliated against her for filing an EEOC complaint
  2. 9 Opposition or participation satisfied pleaded
    Spratt's Amended Complaint sufficiently alleges each element of a retaliation claim under the ADEA.
  3. 10 Judicial material-adversity standard for retaliation satisfied pleaded
    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.
  4. 10 Judicial material-adversity standard for retaliation satisfied pleaded
    An action is materially adverse if it might have 'dissuaded a reasonable worker from making or supporting a charge of discrimination.'
  5. 10 Judicial material-adversity standard for retaliation satisfied pleaded
    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.
  6. 11 Retaliatory causal connection satisfied pleaded
    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.
  7. 11 Retaliatory causal connection satisfied pleaded
    The Court finds that these allegations sufficiently allege a causal link.