Gibbs v. ABT Electronics, Inc.

CourtDistrict Court, N.D. Illinois
DecidedAugust 21, 2025
Docket1:21-cv-06277
StatusUnknown

This text of Gibbs v. ABT Electronics, Inc. (Gibbs v. ABT Electronics, Inc.) 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
Gibbs v. ABT Electronics, Inc., (N.D. Ill. 2025).

Opinion

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

JUSTIN GIBBS,

Plaintiffs, No. 21-cv-06277 v. Judge Georgia N. Alexakis ABT ELECTRONICS, INC. and RICKY ABT,

Defendants.

MEMORANDUM OPINION AND ORDER

Plaintiff Justin Gibbs sued his former employer, defendant Abt Electronics, and its owner, defendant Ricky Abt (collectively “Abt”), under Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, the Illinois Human Rights Act, the Illinois Wage and Payment Collection Act, and the Illinois Biometric Privacy Act (“BIPA”). See generally [19]. Abt moves for partial summary judgment on the BIPA claim [135], arguing that Gibbs has released his BIPA claim in other litigation and that principles of res judicata prevent him from reasserting it here. [135] at 1. For the reasons that follow, the Court grants Abt’s motion for partial summary judgment. 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); 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. Background Gibbs worked for Abt from February 2017 through April 2020. [149] ¶ 1. In the instant suit—filed on November 22, 2021—Gibbs alleged that Abt “required [Gibbs] to have his fingerprints scanned by a biometric timekeeping device each time he had to clock in or out.” [19] ¶ 148; [1]. Gibbs alleges1 that this violated BIPA, because before July 21, 2017, he had not been properly informed that his biometric information was being collected and stored; was not provided with a retention

schedule or guidelines for the destruction of his biometric information; and did not consent in writing to the collection and storage. Id. ¶ 149; 740 ILCS 14/15(a)–(b). More than two years before Gibbs brought this suit, Abt employee Marcus Kardos filed a class-action BIPA suit against Abt in state court. See Kardos v. Abt Electronics Inc, 2019-CH-01235 (Ill. Cir. Ct.). That case concluded with a settlement agreement in which, Abt asserts, Gibbs was identified as a putative class member and, as a result, the Settlement Administrator sent Gibbs notice at his last-known

mailing address. [137] ¶ 17. Gibbs does not deny that class notice was sent but denies that he received any. [149] ¶ 5; [150-1] ¶ 3.

1 Gibbs makes a number of other allegations regarding his treatment while employed at Abt, but because they are not relevant to the instant motion the Court does not discuss them. III. Analysis The Court starts, as it often does at summary judgment, with Local Rule 56.1, which requires the responding party to go paragraph by paragraph, and to explain whether each fact is disputed, and if disputed, to cite the evidentiary material that

disputes the fact. Local Rule 56.1(b)(2), (e)(2)–(3) (N.D. Ill.); see also Kreg Therapeutics, Inc. v. VitalGo, Inc., 919 F.3d 405, 415 (7th Cir. 2019) (explaining that the Northern District’s Local Rule 56.1 “aims to make summary-judgment decisionmaking manageable for courts”). Abt argues that Gibbs has failed to adhere to the rule and thus that its stated facts are undisputed for the purpose of summary judgment. [152] at 2; see Fed. R. Civ. P. 56(e)(2); N.D. Ill. L.R. 56.1(e)(3) (“Asserted

facts may be deemed admitted if not controverted with specific citations to evidentiary material.”); 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.”). But while Gibbs’s reply may be repetitive, it is not procedurally inadequate. The denials to which Abt objects all include the following qualifier: “ … to the extent Defendant claims Plaintiff was a party to the action, as Plaintiff was never a party to

that suit, he was not given notice of the same, nor did Defendant’s counsel notify this Court of the Kardos Matter … thereby waiving its right to pursue a res judicata, claim splitting defense.” [149] ¶¶ 5–36. Whether Gibbs was a party to the Kardos settlement or whether Abt has waived a res judicata argument are of course legal conclusions. But whether Gibbs received actual notice of the Kardos settlement and whether Abt informed Gibbs or the Court of that settlement are facts that Gibbs disputes in the cited declaration. See [150] ¶ 3 (“I was never notified of the state court class action lawsuit, regarding which Defendant claims I am a Plaintiff.”); id. ¶ 7 (“Never once did Defendant’s counsel assert that I was a class action plaintiff until

after the suit had been concluded, over five years after the filing Kardos case and two and a half years after this case.”). It is not clear for its part that Abt actually disputes Gibbs’s assertions that he did not receive notice of the Kardos settlement or that Abt’s counsel did not inform him of that suit. The questions currently before the Court are thus whether Gibbs was a member of the Kardos settlement class and, if so, if there is any reason why he is not bound by that settlement. Gibbs does not argue that he falls outside the class

definition. Nor could he: the settlement class consisted of “[a]ll individuals working or who worked for Abt in the State of Illinois and who had their purported biometric identifier(s) and/or biometric information collected, captured, otherwise obtained … by Abt from January 29, 2014 to September 29, 2019,” a time that includes Gibbs’s employment. [137-1] ¶ 37. Gibbs also does not argue that he excluded himself from or otherwise objected to the settlement agreement, as it provided. Id. ¶¶ 61–62.

Instead, Gibbs argues that he is not bound by the release in the settlement agreement because he never actually received notice of the settlement. [151] at 1, 3. Gibbs does not deny that there was class notification in Kardos, so the remaining question is whether the class notice that issued was sufficient to bind Gibbs. It was. “It is largely irrelevant whether the Plaintiff received actual notice of the class settlement.” Purnell v. Sheriff of Cook Cnty., 07 C 7070, 2009 WL 1210651, at *3 (N.D. Ill. May 4, 2009). Class notice must be “adequate,” but that does not require that every single member of a putative class receive the notice in order to be bound by it. Id. (citing Fontana v. Elrod, 826 F.2d 729, 731–32 (7th Cir. 1987). “In

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Schmidt v. Eagle Waste & Recycling, Inc.
599 F.3d 626 (Seventh Circuit, 2010)
Dinerstein v. Evanston Athletic Clubs, Inc.
2016 IL App (1st) 153388 (Appellate Court of Illinois, 2016)
Spurling v. C & M Fine Pack, Inc.
739 F.3d 1055 (Seventh Circuit, 2014)
Kreg Therapeutics, Inc. v. Vitalgo, Inc.
919 F.3d 405 (Seventh Circuit, 2019)

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Gibbs v. ABT Electronics, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/gibbs-v-abt-electronics-inc-ilnd-2025.