Dunkley v. AFSCME

CourtDistrict Court, S.D. Illinois
DecidedOctober 5, 2021
Docket3:18-cv-02189
StatusUnknown

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

Bluebook
Dunkley v. AFSCME, (S.D. Ill. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

JENNIFER A. DUNKLEY, ) ) Plaintiff, ) ) vs. ) Case No. 3:18-cv-2189-DWD ) LOCAL 2600 AFSCME,1 ) ILLINOIS DEPARTMENT OF ) HUMAN SERVICES, ) KIMBERLY PELTES, and ) MONICA MONROY, ) ) Defendants. )

MEMORANDUM & ORDER DUGAN, District Judge: Plaintiff Jennifer Dunkley worked for the Illinois Department of Humans Services (“IDHS”) from 2015 to 2020. In 2018 and 2019, she brought claims for racial discrimination against IDHS, her labor union AFSCME Local 2600, and other IDHS employees, including Kimberly Peltes and Monica Monroy.2 Now before the Court are motions for summary judgment filed by Defendants AFSCME Local 2600, Kimberly Peltes, and Monica Monroy. (Docs. 188 & 191) The motions are fully briefed and ripe for decision. (Docs. 189, 192, 200, 201, 208, 209) For the following reasons, the motions for summary judgment are due to be granted.3

1 Defendant AFSCME Local 2600 has consistently identified itself as such and not as “Local 2600 AFSCME.” Accordingly, the Clerk of Court is directed to correct Defendant’s name in the docket to “AFSCME Local 2600.” 2 The two cases, 18-cv-2189 and 19-cv-1146, were consolidated on May 28, 2020. (Doc. 76) 3 Dunkley has filed motions to strike Defendants’ reply briefs. (Docs. 210 & 212) And Defendants have filed a joint motion to strike a notice filed by Dunkley regarding her exhibits. (Doc. 215) These motions are also I. FACTUAL BACKGROUND Dunkley began working for IDHS at the Montgomery County Family and Community Resource Center (“Montgomery FCRC”) in 2015 as a Public Aid Eligibility

Assistant. (Doc. 192-6 at 7) She was the only black employee at the Montgomery FCRC and was a member of a bargaining unit represented by AFSCME Local 2600. (Doc. 192-6 at 9) AFSCME Local 2600 is a local union that represents IDHS employees in Sangamon County, Christian County, and Montgomery County. (Doc. 188-10 at 2) Members of AFSCME Local 2600 are covered by a statewide collective bargaining agreement (“CBA”)

between the State of Illinois and AFSCME Council 31, which is a statewide labor organization and is separate from AFSCME Local 2600. (Doc. 188-10 at 3) The first two steps of the CBA’s grievance procedures consist of communicating with the employee’s immediate supervisor and intermediate administrator, and each are handled by AFSCME Local 2600. (Docs. 188-10 at 4 & 188-11 at 20–21) The third and

fourth steps consist of communicating with the agency head and, if unsuccessful, proceeding to pre-arbitration discussions and arbitration. (Doc. 188-11 at 21–22) The third and fourth steps are handled by AFCSME Council 31 and not by AFCSME Local 2600. (Doc. 188-10 at 4) In March 2017, Dunkley contacted AFCSME Local 2600 President Melanie Hoyle

asking to speak to a union representative regarding changes in her duties as a Public Aid

fully briefed. (Docs. 210–16) The Court finds that exceptional circumstances existed justifying Defendants’ reply briefs under Local Rule 7.1(c). Accordingly, Dunkley’s motions to strike are due to be denied. The Court further finds that Dunkley’s notice (Doc. 213) was filed to correct a clerical error and caused no prejudice to Defendants. Accordingly, Defendants’ motion to strike the notice is also due to be denied. Eligibility Assistant. (Doc. 188-10 at 4) Hoyle forwarded the request to Lisa Eden, a union steward, and asked her to respond to it. (Doc. 188-10 at 4) Eden and Dena McGill,

AFSCME Local 2600 Executive Steward, met with Dunkley in late March 2017. (Doc. 188- 10 at 10) At the meeting, Dunkley explained that she felt she was being treated unfairly by her supervisor, Patricia Herker, who was the Local Office Administrator (“LOA”) and who had moved Dunkley out of her private office to an open area. (Doc. 188-10 at 9–10) McGill explained to Dunkley that LOAs “can move the office in whatever way they choose.” (Doc. 188-10 at 22)

On May 10, 2017, Eden was present at a meeting at which Herker gave Dunkley an unfavorable evaluation. (Doc. 188-10 at 11) Eden did not file a grievance regarding the evaluation. (Doc. 188-10 at 11) She does not normally file grievances over evaluations and has never done so on behalf of a non-black union member. (Doc. 188-10 at 11) On May 15, 2017, Harker issued a counseling to Dunkley in a meeting at which Eden was present.

(Doc. 188-10 at 11) Under the CBA, counseling is not considered a disciplinary action. (Doc. 188-11 at 31) AFSCME Local 2600 did not file a grievance after this meeting. (Doc. 38 at 22) Eden told Dunkley that the job might not be a good fit for her and that she should consider looking for other jobs—advice that she has also given to non-black union members. (Doc. 188-10 at 12)

On June 19, 2017, Herker held a pre-disciplinary meeting with Dunkley, at which Eden was present. (Doc. 188-10 at 14) After the meeting, Eden asked Dunkley to let the union review her rebuttal to the meeting before submitting it. (Doc. 188-10 at 14) Dunkley declined to have the union review her rebuttal, citing her belief that Eden had been “relaxing and fraternizing with Patricia Herker, LOA after the meeting,” which Dunkley concluded was “collusion.” (Doc. 188-12 at 33) After Dunkley submitted her rebuttal,

Herker informed her that she was being given a five-day suspension. (Doc. 188-10 at 17) On June 28, 2017, Eden filed a grievance over the suspension. (Doc. 188-10 at 17) Dunkley emailed Hoyle asking her to withdraw the grievance, but Hoyle refused, citing the need to “preserve the integrity of the Master Contract.” (Doc. 188-13 at 16–17) Dunkley’s suspension was reversed and expunged from her record. (Doc. 188-16 at 22) On July 13, 2017, Herker met with Dunkley and issued her an oral reprimand, and

Dunkley signed a document waiving union representation at the meeting. (Docs. 188-10 at 18 & 188-13 at 34) Eden does not recall Dunkley requesting a grievance be filed over the oral reprimand, and Eden did not file a grievance over the oral reprimand. (Doc. 188- 10 at 19) On August 7, 2017, Herker gave Dunkley a seven-day suspension. (Doc. 188-5 at 7) Eden suggested that Dunkley could file a grievance based on failure to follow

progressive discipline. (Doc. 188-5 at 12) But Dunkley requested that a grievance be filed for falsification. (Doc. 188-5 at 14) Eden investigated Dunkley’s claim of falsification but found that it could not be substantiated and did not file a grievance over her seven-day suspension. (Doc. 188-10 at 20) In the fall of 2017, Eden negotiated with IDHS labor relations liaison Rick Starr for

Dunkley to be transferred to the Marion County Family and Community Resource Center (“Marion FCRC”). (Doc. 188-10 at 21–22) Dunkley was transferred to the Marion FCRC in October 2017. (Doc. 188-10 at 24) Next, Dunkley worked for IDHS at the Madison County/East Alton Family and Community Resource Center (“Madison FCRC”) from September 2018 to August 2019 as a Social Services Career Trainee. (Doc. 192-1 at 1 & 6) A trainee serves a probationary period of up to 12 months and can be certified as a

Human Services Caseworker six to 12 months after the beginning of the probationary period. (Doc. 192-1 at 2) During the probationary period, a trainee learns to process and certify applications for public assistance. (Doc. 192-1 at 2) When trainees are learning to certify cases, all of their work is subject to review, known as “one hundred percent review.” (Doc. 192-1 at 3) The review may be reduced depending on the trainee’s progress. (Doc. 192-1 at 3) Peltes was Dunkley’s direct supervisor while Dunkley was a

trainee at the Madison FCRC and was responsible for reviewing Dunkley’s work during her probationary period. (Doc. 192-1 at 1 & 3) Dunkley attended a caseworker training course on November 27–30, 2018. (Doc.

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