United States District Court for the Northern District of Illinois · 2019-05-21
29usc623: author: Astra4 · not independently reviewed
Case and law context
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
| Case | Employer coverage and exclusions | Age forty or older | Hiring discharge or employment terms | Judicial but-for standard for age-based treatment | Route-conditioned statutory f(1) and f(2) alternatives | Conditional 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
| Case | Age sixty-five executive or high-policymaker compulsory retirement | Judicial impact requirement to identify a particular practice | Judicial impact requirement of significant causal disparity | Covered employment agency | Covered labor organization | Opposition 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
| Case | Judicial material-adversity standard for retaliation | Retaliatory causal connection | Agency referral discrimination | Membership classification referral or causing discrimination | Employer agency or union advertiser | Age-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
| Case | Wage reduction to comply | Employer agency union or combination maintaining a pension plan | Establish or maintain an employee pension benefit plan | Age-based accrual or allocation cessation or reduction | Subsection i pension qualifications and compliance | Conditional 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
| Case | Narrow bona fide occupational qualification | Displayed scope and specialized exclusions | Charge filing waiver and remedies | Foreign workplace conflict with local law | Good cause for employer discharge or discipline | Judicial 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
| Case | Reasonable 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
| Case | Element | Holding and scope | Pattern | Exact 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 participation | satisfied 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 complaintSource: docroot/ir/caselaw/f_supp_3d_380.jsonl#/f-supp-3d/380/0783-01; Unicode character offsets [6455:6535] (end exclusive); SHA-256 ae65194fc22e806d299e7b218c92596a3be1c881f1451e66c47790b7cf1aad24.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. |
| 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 connection | satisfied 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.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. |
| 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 retaliation | satisfied 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.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.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. |