McLaughlin v. Cook County

2023 IL App (1st) 221869
CourtAppellate Court of Illinois
DecidedOctober 20, 2023
Docket1-22-1869
StatusPublished
Cited by1 cases

This text of 2023 IL App (1st) 221869 (McLaughlin v. Cook County) 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
McLaughlin v. Cook County, 2023 IL App (1st) 221869 (Ill. Ct. App. 2023).

Opinion

2023 IL App (1st) 221869 No. 1-22-1869 Order filed October 20, 2023

Fifth 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 JUDICIAL DISTRICT

ELAINE MCLAUGHLIN, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County. ) v. ) No. 2020 L 7840 ) COOK COUNTY, ) Honorable James E. Snyder, ) Judge, Presiding. Defendant-Appellee. )

JUSTICE NAVARRO delivered the judgment of the court. Presiding Justice Mitchell and Justice Lyle concurred in the judgment.

ORDER

¶1 Held: The circuit court properly granted summary judgment in favor of defendant where plaintiff failed to present sufficient evidence to support her claims of gender discrimination based on her being paid less than other male employees under the Illinois Equal Pay Act and Illinois Human Rights Act; affirmed.

¶2 Plaintiff, Elaine McLaughlin, appeals from the circuit court’s order that granted

summary judgment in favor of defendant, Cook County, and dismissed her complaint, which

alleged claims of gender discrimination based on her being paid less than other male employees

under the Illinois Human Rights Act (IHRA) (775 ILCS 5/1-101, et. seq.) (West 2020)) and Illinois

Equal Pay Act of 2003 (IEPA) (820 ILCS 112/1 et. seq.) (West 2020)). On appeal, plaintiff argues

that the circuit court erred when it granted summary judgment in favor of defendant on her IHRA No. 1-22-1869

claims because there are questions of fact regarding whether she performed all of the duties of her

male supervisor. She also argues that she was similarly situated to her supervisor and her male

colleague and that they were treated more favorably by receiving higher salaries. Plaintiff further

contends the court erred when it granted summary judgment in favor of defendant on her IEPA

claims because she presented sufficient evidence to establish she performed equal work as her

supervisor, had similar skill and responsibilities, and performed the work under similar conditions.

We affirm.

¶3 I. BACKGROUND

¶4 Complaint

¶5 Plaintiff’s second amended complaint, the pleading at issue here, contained two claims

for gender discrimination under the IHRA and two claims for gender discrimination under the

IEPA.1 Plaintiff alleged that since 2010, she was an administrative analyst IV in the Cook County’s

Department of Transportation and Highways (DOTH). Her duties were to assist the contract

administrator with the formal communications with the Clerk of the Board of Cook County

Commissions regarding, among other things, construction, road maintenance resolutions, contract

lettings, changes and final acceptances. Plaintiff alleged that in addition to performing her duties

as administrative analyst IV, defendant also required her to perform the duties for the positions of

contract administrator, senior contract administrator, contract manager, and procurement buyer.

She was paid less than the male employees who occupied these positions, and she did not receive

additional salary for performing these other duties.

¶6 In defendant’s first affirmative defense, it asserted it uses a merit-based pay system

consisting of a corresponding pay scale for positions based on their “Grade” and that generally

1 Plaintiff also alleged a claim for retaliation under the IHRA, which the court dismissed, and is not at issue on appeal.

-2- No. 1-22-1869

higher grade positions have a higher scale. It asserted that employees may receive periodic

increases in pay called “step increases.” Defendant stated that in April 2002, plaintiff was hired as

an administrative analyst V, a grade 20 position. In June 2010, plaintiff started as an administrative

analyst IV, a grade 22 position. Plaintiff’s supervisor, Thomas Gavin, was a contract administrator,

a grade 23 position. Plaintiff and Gavin received periodic step increases based on the merit-based

system.

¶7 In defendant’s second affirmative defense, it asserted that in April 2021, it posted

openings for two contract manager positions on its public, online job board and that plaintiff did

not apply for the positions.

¶8 Summary Judgment Proceedings

¶9 Defendant filed a motion for summary judgment, asserting in part that plaintiff’s IEPA

claims fail because she did not perform the same job as her supervisor or colleague and because

Cook County pays its employees on a merit-based pay system where an employee’s salary is based

on grades and steps. Defendant also argued that plaintiff’s IHRA claims fail for the same reasons

and because plaintiff presented no evidence that defendant treated her differently because of her

gender. Defendant asserted that plaintiff did not have any evidence to support her IHRA or IEPA

gender discrimination claims.

¶ 10 Defendant submitted the affidavits and depositions of several witnesses with its motion.

We summarize the affidavits, depositions, and other documents that were attached to

defendant’s motion.

¶ 11 Jennifer Killen, the current superintendent of the DOTH and assistant superintendent

of the DOTH from 2012 to April 2021, stated in her affidavit that plaintiff worked as a grade 22

administrative analyst IV in the contract documents division in the Administrative and Fiscal

-3- No. 1-22-1869

Management Bureau of the DOTH. As an administrative analyst IV, plaintiff assisted Gavin in

performing the contract administrator duties related to road construction. Plaintiff was one of the

most highly paid employees at DOTH.

¶ 12 Killen averred that Gavin’s written job description had not been updated during his

time at DOTH and that his job description did not include additional responsibilities assigned to

him as the contract documents division evolved. In addition to road construction, Gavin also was

responsible for professional engineering contracts. Plaintiff only worked on contract documents

for road construction and did not work on the professional engineering consulting contracts. Gavin

had supervisory duties, and plaintiff did not supervise any employees.

¶ 13 Killen further stated that defendant must adhere to the “Employment Plan” and may

only interview candidates who apply and interview for posted positions. On April 1, 2021,

employees at the DOTH, including plaintiff, received an email invitation to apply for the two

newly created contract manager positions. Plaintiff did not apply for one of the contract manager

positions. The DOTH hired Cho Ng, a male, and Brenda Chagoya, a female, for the positions.

¶ 14 Defendant also attached to its motion for summary judgment the County of Cook

Personnel Rules effective February 19, 2020, which provide the rules for position classification

and compensation for employees and describe the salary grade and step system under which

employees are paid. Under rule two, a new employee’s salary is based on the salary grade in which

the position is in, and an employee must be paid the minimum salary provided in the salary step in

which the job is placed. The rule states that eligibility for “longevity step advancement” and

“longevity step placement” must conform “with the years of service requirements established in

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Cite This Page — Counsel Stack

Bluebook (online)
2023 IL App (1st) 221869, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mclaughlin-v-cook-county-illappct-2023.