Michael Tallon v. United Airlines, Inc., Air Line Pilots Association, Dr. Robert Noven, and Dr. Stafford Henry

District Court, N.D. Illinois·Decided August 10, 2026·No. 1:25-cv-07529·Unknown

Opinion

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

Michael Tallon, ) ) Plaintiff, ) ) No. 25 C 7529 v. ) ) Judge Jorge L. Alonso ) United Airlines, Inc., Air Line Pilots ) Association, Dr. Robert Noven, and Dr. ) Stafford Henry, ) ) Defendants. )

Memorandum Opinion and Order Plaintiff, Michael Tallon, a former pilot for United Airlines, Inc. (“United”), brings this suit against his former employer, his union, and two medical professionals who examined him, asserting claims of disability discrimination, civil RICO, and intentional torts governed by state law. His claims arise out of his enrollment in a substance-abuse treatment program administered by his employer, which he claims to have been needlessly forced to undergo. The defendants have moved to dismiss under Federal Rule of Civil Procedure 12(b). For the following reasons, the motions to dismiss are granted. I. Background For purposes of the present motion to dismiss, the Court assumes the truth of the following factual allegations contained in the operative complaint. On June 10, 2023, while on a layover in the Azores, Plaintiff tripped on an uneven sidewalk and suffered a head injury. A colleague afterward observed his deteriorating speech and confusion. At one point that evening, Plaintiff called his wife and asked to speak to his mother, which alarmed Plaintiff’s wife—his mother had passed away twenty years earlier. Plaintiff called a United manager and asked to be removed from flight duty the next day. Plaintiff also spoke with Margaret Hendrix, who serves as United’s Air Line Pilots Association, International (“ALPA”) representative on the Human Intervention Motivation Study

(“HIMS”) Steering Committee. HIMS is a collaborative substance-abuse treatment program developed by the Federal Aviation Administration (“FAA”), in cooperation with various airlines and ALPA, a labor union representing airline pilots, including Plaintiff. The HIMS program “provide[s] a system whereby afflicted individuals [with alcoholism or other substance use disorders] are treated and successfully returned to the cockpit under the FAA Special Issuance Regulations (14 CFR 67.401).”1 Under FAA regulations, airline pilots need a medical certificate to fly, and they may not hold a first-class medical certificate such as Plaintiff’s if they have an “established medical history or clinical diagnosis of . . . [s]ubstance dependence.” 14 C.F.R § 67.107(a)(4). However, “[a]t the discretion of the Federal Air Surgeon,” who exercises authority delegated to him by the FAA Administrator, “an Authorization for a Special Issuance of a Medical

Certificate . . . may be granted to a person” who does not otherwise qualify for a medical certificate. Id. § 67.401(a). The HIMS program provides a process for pilots who have struggled with addiction to demonstrate that they can safely return to work via a Special Issuance Authorization. When Plaintiff spoke to Hendrix on June 10, 2023, he was “disoriented and confused,” in a “concussed fog” (Am. Compl. ¶¶ 18-19), and his recollection of their phone conversation is fuzzy. Hendrix said afterward that he told her that he needed help with his drinking. The following day, Plaintiff flew home as a passenger. Upon his return, United and ALPA representatives called him and pressured him to admit to alcoholism. He denied that he had an

1 https://himsprogram.com/about-hims/. alcohol problem, but Hendrix warned him that, if he did not confess to a drinking problem, he would never fly for United again. Plaintiff received no care for his head injury. Instead, Hendrix arranged for him to enroll in an inpatient treatment program for alcoholism. Plaintiff had an upcoming appointment with an Aviation Medical Examiner (“AME”) for

renewal of his medical certificate, but United and ALPA induced him to cancel that appointment and instead submit to an evaluation by a psychiatrist, Dr. Stafford Henry. Dr. Henry did not examine Plaintiff for a head injury, but did interview him and administer tests relevant to whether he suffered from alcoholism. Although there was no physical evidence of alcohol dependence in any of Dr. Henry’s test results, Dr. Henry spoke to “collateral sources,” and he wrote a report in which he opined that “the totality of all available clinical information . . . supports the diagnosis of alcohol dependence, per FAR’s (i.e. ‘Drinking in larger amounts and over longer periods than intended.’).” (Henry Report, ALPA Mot. App. 27, Dkt. No. 48-1.) “FAR’s” stands for “federal aviation regulations.” Dr. Henry explained that he spoke with numerous sources who knew Plaintiff and purported to be familiar with his drinking habits, some of whom suggested that he

did not have a drinking problem, and some of whom suggested, based on what they had observed and what Plaintiff told them, that he did. (Id. App. 36-39.) Based on these accounts and the “totality of all available clinical information,” Dr. Henry reached the conclusion that “a diagnosis of Alcohol Dependence, per FAR’s,” was “appropriate.” (Id. App. 42.) Plaintiff contacted John Hanson, an ALPA attorney, and asked to challenge Dr. Henry’s report, pursuant to his rights under the collective bargaining agreement (“CBA”) between United and ALPA. Hanson warned Plaintiff that challenging the report or securing outside representation to do so would look like denial, would likely result in harsh treatment, and could lead to termination. On August 28, 2023, Plaintiff entered an inpatient treatment facility known as High Watch Recovery Center (“High Watch”) in Connecticut, where he remained for twenty-eight days. On September 21, 2023, while Plaintiff was still at High Watch, he met with Hendrix and two United representatives: James Bono, the chief pilot in Chicago, and Jen Wegener, an

Employee Assistance Program (“EAP”) representative. Hendrix, Bono, and Wegener instructed Plaintiff to sign a contract to enter United’s HIMS program. Plaintiff was reluctant because he did not believe he had an alcohol problem, but he was told that he would be fired if he did not sign. He signed the contract under “coercion and duress.” (Am. Compl. ¶ 37.) The contract provided that Plaintiff would “comply with the [HIMS] program requirements,” and that failure to do so could result in “loss of benefits, a recommendation for [Special Issuance] revocation, or termination from the company.” (HIMS Compliance Contract, ALPA Mot. App. 44, Dkt. No. 48- 1.) Plaintiff was discharged from High Watch on September 25, 2023. He was not diagnosed with an alcohol use disorder by anyone who examined him at High Watch. United or ALPA (Plaintiff does not know which) submitted a false claim form to an insurer

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Michael Tallon v. United Airlines, Inc., Air Line Pilots Association, Dr. Robert Noven, and Dr. Stafford Henry, (N.D. Ill. 2026).

Michael Tallon v. United Airlines, Inc., Air Line Pilots Association, Dr. Robert Noven, and Dr. Stafford Henry (Michael Tallon v. United Airlines, Inc., Air Line Pilots Association, Dr. Robert Noven, and Dr. Stafford Henry) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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