Brown v. Chicago Transit Authority

CourtDistrict Court, N.D. Illinois
DecidedMarch 31, 2025
Docket1:22-cv-00675
StatusUnknown

This text of Brown v. Chicago Transit Authority (Brown v. Chicago Transit Authority) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Chicago Transit Authority, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

RUSSIA BROWN,

Plaintiff, No. 22 CV 675 v. Judge Georgia N. Alexakis CHICAGO TRANSIT AUTHORITY and AMALGAMATED TRANSIT UNION LOCAL 241

Defendants.

MEMORANDUM OPINION AND ORDER

Plaintiff Russia Brown, a former bus operator for the Chicago Transit Authority (“CTA”), was terminated after CTA concluded that he falsified leave under the Family and Medical Leave Act (“FMLA”). Brown sued CTA and his union, Amalgamated Transit Union Local 241 (“Local 241”), for unlawful discrimination on the basis of his gender identity in violation of Title VII of the Civil Rights Act of 1964, alleging that his firing had been pretextual and that his union had failed to properly advocate for him. Local 241 now moves for summary judgment. [110]. For the reasons given below, that motion is granted.1 I. Legal Standards Summary judgment is appropriate if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law. Spurling v. C & M Fine Pack, Inc., 739 F.3d 1055, 1060 (7th Cir. 2014);

1 The Court addresses CTA’s motion for summary judgment in a separate memorandum opinion and order issued this same day. Fed. R. Civ. P. 56(a). A genuine dispute as to any material fact exists if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). The party seeking summary

judgment has the burden of establishing that there is no genuine dispute as to any material fact. See Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). II. Threshold Issues A. Local Rule 56.1 Statements & Statements of Additional Fact At summary judgment, the local rules require that the moving party serve “a statement of material facts as to which the moving party contends there is no genuine issue and that entitles the moving party to a judgment as a matter of law.” N.D. Ill. L.R. 56.1(a)(3); see also Cracco v. Vitran Express, Inc., 559 F.3d 625, 632 (7th Cir.

2009). The opposing party must then file a response to the movant’s statement of material facts and may also assert any additional facts they wish not already set forth. N.D. Ill. L.R. 56.1(b)(2). Any facts asserted “must consist of concise numbered paragraphs” and “be supported by citation to the specific evidentiary material, including the specific page number, that supports it.” N.D. Ill. R. 56.1(d). “Asserted facts may be deemed admitted if not controverted with specific citations to

evidentiary material.” N.D. Ill. L.R. 56.1(e)(3). Local 241 argues that Brown’s Rule 56.1 response and statement of additional facts [125] fails to properly support certain facts, see, e.g., [135] at 8 n.4, and repeatedly fails to comply with the Rule 56.1(d)(1) requirement of “concise numbered paragraphs.” The Court agrees that Brown’s response and statement of additional facts suffers from these violations. Many paragraphs are improperly padded with multiple facts in violation of Local Rule 56.1(d)(1), which requires “concise numbered paragraphs.” See, e.g., [136] ¶¶ 2–8. On other occasions, Brown fails to properly support certain facts with record evidence. See, e.g., [136] ¶ 27 (Brown appears to cite

to [127-9] for content of a text message conversation between a union representative and the union president, but the exhibit does not support the asserted facts); id. ¶ 16 (Brown alleges that initial CTA charging documents did not indicate Brown was being accused of FMLA falsification for failing to follow proper call-out procedures, but cited documents, see [127-8] at 3, specifically reference FMLA “falsification” and note that “there was no notification to the third party Reed” on 24 occasions).2 The Court is entitled to insist on “strict compliance” with the local rules.

Cracco, 559 F.3d at 623 (cleaned up); see also Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir. 2010). (“[A] district court may strictly enforce compliance with its local rules regarding summary judgment motions.”). Where Brown has failed to comply with these rules—and, most significantly, where Brown has failed to support asserted facts with on-the-mark record evidence—the Court will treat properly asserted and supported facts in Local 241’s filings as undisputed for

2 Even more confusingly, in response to a separate asserted fact, Brown “does not dispute” that he was taken out-of-service without pay because he “falsified FMLA” and “had not followed the correct call-out procedure.” [126] ¶ 30. the purpose of summary judgment. See Fed. R. Civ. P. 56(e)(2); N.D. Ill. L.R. 56.1(e)(3).3 B. Admissibility Some of Brown’s response and statement of additional facts presents

admissibility concerns, which the Court addresses at the outset. See Fed. R. Civ. P. 56(c)(2) (“A party may object that the material cited to support or dispute a fact cannot be presented in a form that would be admissible in evidence.”); [135] at 13 (Local 241 objects to Brown’s reliance on hearsay to oppose its motion for summary judgment).4 First, Local 241 argues that Brown relied on inadmissible hearsay to allege

that Local 241 President Keith Hill made certain statements to CTA manager Jairo Naranjo, who then related the conversation with Hill to another CTA manager, Gregory Middleton, on whose deposition Brown relies for Hill’s statements. [135] at 13; [136] ¶¶ 5, 14. This is classic hearsay under Federal Rule of Evidence 801(c)—it is offered for the truth of whether Hill made the statements—and because CTA and

3 As the Court notes in its accompanying memorandum opinion and order on CTA’s motion for summary judgment, counsel for Brown also failed to comply with local rules on summary judgment in opposing that motion. Local Rule 56.1 “aims to make summary-judgment decisionmaking manageable for courts.” Kreg Therapeutics, Inc. v. VitalGo, Inc., 919 F.3d 405, 415 (7th Cir. 2019). A repeated failure to comply with the rule undermines this objective and needlessly expends the judiciary’s resources. Counsel is admonished to strictly adhere to Local Rule 56.1 going forward.

4 Brown objects to hearsay use by Local 241, see [125] at 11, but unlike Local 241, Brown does not specify what inadmissible statements he is referring to. In the same vein, Brown does not attempt to defend his use of hearsay (e.g., by pointing the Court to a potentially applicable exception under Fed. R. Evid. 803). The Court will not turn a blind eye to patently inadmissible material. Nor will it exclude evidence that is clearly admissible under an obvious exception to the hearsay rule. At the same time, it is not this Court’s job to craft legal arguments for a party. See Kathrein v. City of Evanston, Ill., 752 F.3d 680, 689 (7th Cir. 2014).

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