Bianchi v. The Human Rights Comm'n

2026 IL App (1st) 241474-U
CourtAppellate Court of Illinois
DecidedMarch 6, 2026
Docket1-24-1474
StatusUnpublished

This text of 2026 IL App (1st) 241474-U (Bianchi v. The Human Rights Comm'n) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bianchi v. The Human Rights Comm'n, 2026 IL App (1st) 241474-U (Ill. Ct. App. 2026).

Opinion

2026 IL App (1st) 241474-U No. 1-24-1474 Order filed March 6, 2026 Sixth Division

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ DONALD BIANCHI, ) Petition for Direct ) Administrative Review of a Petitioner-Appellant, ) Decision of the Human Rights ) Commission. v. ) ) No. 19 CA 1426 THE HUMAN RIGHTS COMMISSION and EXELON ) (COMMONWEALTH EDISON CO.), ) ) Respondents-Appellees. )

JUSTICE GAMRATH delivered the judgment of the court. Presiding Justice C.A. Walker and Justice Hyman concurred in the judgment.

ORDER

¶1 Held: We affirm the decision of the Illinois Human Rights Commission where petitioner failed to establish a prima facie case of termination based on unlawful discrimination.

¶2 Petitioner Donald Bianchi filed a discrimination complaint with the Illinois Human Rights

Commission, alleging Exelon (ComEd) terminated him because of his race, age, and disability in

violation of the Illinois Human Rights Act (775 ILCS 5/1-101 et seq. (West 2018)). An No. 1-24-1474

administrative law judge (ALJ) dismissed the complaint with prejudice, the Commission adopted

that decision, and Bianchi appealed. We affirm.

¶3 Bianchi worked for ComEd from 1999 until his 2018 termination. As a crew leader, he was

responsible for overseeing and assisting teams of employees to build and maintain electrical power

systems. ComEd asserts Bianchi was terminated due to safety violations that made him a “risk to

his crew and himself.”

¶4 On May 4, 2016, Bianchi and his crew were replacing an underground transformer which

required creating and enforcing a “zone of protection” where “six isolation points needed to be

tagged and grounded.” Bianchi’s crew only tagged and grounded three locations in violation of

ComEd’s safety rules. Bianchi admitted rushing the job and was suspended for 20 days and

demoted.

¶5 On February 16, 2018, after being promoted back to crew leader, Bianchi again violated

safety rules by cutting a live primary cable without testing it or using grounded equipment, causing

a blown fuse and power outage. ComEd terminated him effective March 7, 2018.

¶6 Bianchi filed a charge of discrimination with the Illinois Department of Human Rights,

which did not issue an investigative report within 365 days in violation of section 7A-102 of the

Act (775 ILCS 5/7A-102(G)(1) (West 2018)). This allowed Bianchi to proceed before the

Commission. Id. § 7A-102(G)(2).

¶7 In his Commission complaint, Bianchi alleged he was terminated because he is Caucasian,

age 48, and has bipolar disorder, and that younger, non-Caucasian, or non-disabled employees

committed similar errors without being fired. Bianchi’s attached notes identified employees who

allegedly committed similar safety violations and were not terminated. However, Bianchi did not

-2- No. 1-24-1474

identify their races or ages. He also cited comments from his supervisor Scott Nicholson and others

that he believed referenced his mental health, though his medical records from 2002 and 2004 did

not reference bipolar disorder.

¶8 On September 27, 2023, ComEd filed a motion for summary decision, supported by

declarations and Bianchi’s deposition. In it, ComEd argued Bianchi could not establish race or age

discrimination because he failed to identify similarly situated non-Caucasian or younger

employees who were treated more favorably and he offered no evidence that ComEd’s proffered

legitimate and non-discriminatory explanation for his termination was pretextual. Bianchi also

could not establish disability discrimination because he could not identify anyone at ComEd who

knew that he was, or perceived him to be disabled, or that his disability served as the basis for his

termination.

¶9 On October 30, 2023, the ALJ issued a recommended order and decision granting ComEd’s

motion, finding “no genuine issue of material fact exists in this matter, and that [Bianchi] is unable

to advance a prima facie case of discrimination on the basis of disability, race, or age.” The ALJ

found that Bianchi failed to establish a prima facie case of race or age discrimination because he

did not submit evidence, counter-affidavits, or a response in opposition to ComEd’s motion that

would show that a similarly-situated employee outside of his protected classes was treated better

under similar circumstances to those that resulted in his termination. Specifically, the ALJ found

that none of the employees Bianchi named in his complaint and deposition supported his claims

because the employees were Caucasian and older than him and were not outside his protected

classes. ComEd also reported that it had no record of one of the employees Bianchi claimed

committed the same safety violation. The ALJ further found that, even assuming Bianchi could

-3- No. 1-24-1474

make a prima facie case, he could not show that ComEd’s stated reason for firing him (repeated

safety violations) was pretextual.

¶ 10 The ALJ likewise held that Bianchi failed to establish a prima facie case of disability

discrimination because he was unable to show that Nicholson knew or believed Bianchi had a

disability. Nicholson offered an uncontested statement that he neither knew nor perceived any

disability when he referred Bianchi for termination. He was also unaware of doctor’s notes or

medical records detailing a disability. Bianchi’s own medical documents failed to mention bipolar

disorder, and ComEd submitted forms signed by Bianchi stating that he did not suffer from any

disorders or mental health issues. The ALJ concluded this unrefuted evidence “foreclosed any

possibility that Nicholson could have believed or perceived that [Bianchi] was bipolar.” Moreover,

Bianchi’s interpretation of the alleged comments referencing his disability was speculative and

“insufficient to avoid summary judgment.” The ALJ also noted that Bianchi’s failure to respond

to ComEd’s motion for summary decision would have warranted dismissal for want of prosecution

even apart from the merits.

¶ 11 Bianchi requested review of the ALJ’s decision due to noncompliance with “ADA *** due

to [his] disability.” The Commission declined further review and adopted the ALJ’s recommended

order and decision as the “[o]rder of the Commission.”

¶ 12 On appeal, Bianchi argues that the Commission erred in granting ComEd’s motion for

summary decision and dismissing his complaint of discrimination where he established that he was

terminated due to his disability.

¶ 13 To start, while Bianchi’s notice of appeal states that he is appealing from the Commission’s

decision granting ComEd’s motion for summary decision and dismissing his complaint of

-4- No. 1-24-1474

discrimination based on race, age, and disability, his brief only references his alleged disability. 1

Therefore, we address Bianchi’s contentions as to that issue only, and any arguments pertaining to

race or age are waived. See Multiut Corp. v. Draiman, 359 Ill. App. 3d 527, 539 (2005) (“[i]ssues

raised in the notice of appeal but not raised or argued to this court are generally deemed waived”).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Zaderaka v. Illinois Human Rights Commission
545 N.E.2d 684 (Illinois Supreme Court, 1989)
Multiut Corp. v. Draiman
834 N.E.2d 43 (Appellate Court of Illinois, 2005)
Sola v. Illinois Human Rights Comm'n
736 N.E.2d 1150 (Appellate Court of Illinois, 2000)
Kreczko v. Triangle Package Machinery Co.
2016 IL App (1st) 151762 (Appellate Court of Illinois, 2016)
GreenPoint Mortgage Funding, Inc. v. Hirt
2018 IL App (1st) 170921 (Appellate Court of Illinois, 2018)
Givens v. City of Chicago
2023 IL 127837 (Illinois Supreme Court, 2023)
McLaughlin v. Cook County
2023 IL App (1st) 221869 (Appellate Court of Illinois, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2026 IL App (1st) 241474-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bianchi-v-the-human-rights-commn-illappct-2026.