Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019

United States District Court for the Northern District of Illinois · 2019-05-21

29usc623: author: Astra4 · not independently reviewed

Original case on neochart.com

Case and law context

29 U.S.C. §§ 621–634

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

Uncertainty

None recorded

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.

B · Case × element grid

Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.

Elements 1–6 of 31

29 U.S.C. §§ 621–634
CaseEmployer coverage and exclusionsAge forty or olderHiring discharge or employment termsJudicial but-for standard for age-based treatmentRoute-conditioned statutory f(1) and f(2) alternativesConditional state firefighter and law-enforcement hiring or retirement
Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019 (29usc623: author: Astra4 · not independently reviewed)· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 7–12 of 31

29 U.S.C. §§ 621–634
CaseAge sixty-five executive or high-policymaker compulsory retirementJudicial impact requirement to identify a particular practiceJudicial impact requirement of significant causal disparityCovered employment agencyCovered labor organizationOpposition or participation
Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019 (29usc623: author: Astra4 · not independently reviewed)· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 13–18 of 31

29 U.S.C. §§ 621–634
CaseJudicial material-adversity standard for retaliationRetaliatory causal connectionAgency referral discriminationMembership classification referral or causing discriminationEmployer agency or union advertiserAge-based notice or advertisement
Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019 (29usc623: author: Astra4 · not independently reviewed)· not addressed· not addressed· not addressed· not addressed

Elements 19–24 of 31

29 U.S.C. §§ 621–634
CaseWage reduction to complyEmployer agency union or combination maintaining a pension planEstablish or maintain an employee pension benefit planAge-based accrual or allocation cessation or reductionSubsection i pension qualifications and complianceConditional bona fide seniority system or benefit plan
Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019 (29usc623: author: Astra4 · not independently reviewed)· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 25–30 of 31

29 U.S.C. §§ 621–634
CaseNarrow bona fide occupational qualificationDisplayed scope and specialized exclusionsCharge filing waiver and remediesForeign workplace conflict with local lawGood cause for employer discharge or disciplineJudicial outside-applicant coverage limit where circuit precedent controls
Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019 (29usc623: author: Astra4 · not independently reviewed)· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 31–31 of 31

29 U.S.C. §§ 621–634
CaseReasonable factors other than age
Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019 (29usc623: author: Astra4 · not independently reviewed)· not addressed

Instances and excluded annotation blocks

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopePatternExact source quotations
Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019 — satisfied · pleaded (29usc623: author: Astra4 · not independently reviewed)Opposition or participationsatisfied
Counted merits instance
applied / merits

basis: pleaded

The pleaded retaliation allegation survived the motion to dismiss posture.
eeoc-age-discrimination-charge
Spratt alleges that Bellwood retaliated against her for filing an EEOC complaint
Source: docroot/ir/caselaw/f_supp_3d_380.jsonl#/f-supp-3d/380/0783-01; Unicode character offsets [6455:6535] (end exclusive); SHA-256 ae65194fc22e806d299e7b218c92596a3be1c881f1451e66c47790b7cf1aad24.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Spratt's Amended Complaint sufficiently alleges each element of a retaliation claim under the ADEA.
Source: docroot/ir/caselaw/f_supp_3d_380.jsonl#/f-supp-3d/380/0783-01; Unicode character offsets [7368:7467] (end exclusive); SHA-256 ae65194fc22e806d299e7b218c92596a3be1c881f1451e66c47790b7cf1aad24.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019 — satisfied · pleaded (29usc623: author: Astra4 · not independently reviewed)Retaliatory causal connectionsatisfied
Counted merits instance
applied / merits

basis: pleaded

Temporal proximity and the alleged nine-month retaliatory course adequately pleaded causation.
causation/charge-followed-by-continuing-pattern
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.
Source: docroot/ir/caselaw/f_supp_3d_380.jsonl#/f-supp-3d/380/0783-01; Unicode character offsets [8819:9067] (end exclusive); SHA-256 ae65194fc22e806d299e7b218c92596a3be1c881f1451e66c47790b7cf1aad24.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

The Court finds that these allegations sufficiently allege a causal link.
Source: docroot/ir/caselaw/f_supp_3d_380.jsonl#/f-supp-3d/380/0783-01; Unicode character offsets [9213:9286] (end exclusive); SHA-256 ae65194fc22e806d299e7b218c92596a3be1c881f1451e66c47790b7cf1aad24.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Spratt v. Bellwood Public Library — 380 F. Supp. 3d 783 (2019) · United States District Court for the Northern District of Illinois · 2019 — satisfied · pleaded (29usc623: author: Astra4 · not independently reviewed)Judicial material-adversity standard for retaliationsatisfied
Counted merits instance
applied / merits

basis: pleaded

The court accepted the pleaded leave, constructive discharge, and termination as materially adverse at Rule 12(b)(6).
retaliation/leave-and-termination-after-charge
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.
Source: docroot/ir/caselaw/f_supp_3d_380.jsonl#/f-supp-3d/380/0783-01; Unicode character offsets [7611:7875] (end exclusive); SHA-256 ae65194fc22e806d299e7b218c92596a3be1c881f1451e66c47790b7cf1aad24.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

An action is materially adverse if it might have 'dissuaded a reasonable worker from making or supporting a charge of discrimination.'
Source: docroot/ir/caselaw/f_supp_3d_380.jsonl#/f-supp-3d/380/0783-01; Unicode character offsets [7877:8011] (end exclusive); SHA-256 ae65194fc22e806d299e7b218c92596a3be1c881f1451e66c47790b7cf1aad24.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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.
Source: docroot/ir/caselaw/f_supp_3d_380.jsonl#/f-supp-3d/380/0783-01; Unicode character offsets [8472:8709] (end exclusive); SHA-256 ae65194fc22e806d299e7b218c92596a3be1c881f1451e66c47790b7cf1aad24.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations recorded from this case