Morehouse v. Canadian National Railway Co.

CourtDistrict Court, N.D. Illinois
DecidedMarch 28, 2025
Docket1:21-cv-04213
StatusUnknown

This text of Morehouse v. Canadian National Railway Co. (Morehouse v. Canadian National Railway Co.) 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
Morehouse v. Canadian National Railway Co., (N.D. Ill. 2025).

Opinion

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

ANNE MOREHOUSE,

Plaintiff, No. 21-cv-04213 v. Judge John F. Kness CANADIAN NATIONAL RAILWAY CO. and ILLINOIS CENTRAL RAILROAD CO.,

Defendants.

MEMORANDUM OPINION AND ORDER Plaintiff Anne Morehouse, who was previously employed at the Illinois Central Railroad Company, filed an Amended Complaint (“Complaint”) alleging claims under 42 U.S.C. § 2000e et seq. (“Title VII”) of sex discrimination and retaliation against the Illinois Central Railroad Company and Canadian National Railway Company (“Defendants”), along with a claim under 29 U.S.C. § 206(d) (“Equal Pay Act”). Defendants have moved to dismiss the Complaint. Defendants argue that Plaintiff’s Title VII (Counts I and II) claims should be dismissed as untimely, and that the Equal Pay Act (Count III) claim should be dismissed because Plaintiff fails to state a claim for relief. As explained below, although Plaintiff’s Title VII claims may turn out to be untimely once the factual record is developed, Defendants’ affirmative defense based on lack of a timely suit cannot be resolved at the pleading stage. Conversely, Plaintiff has not stated a viable claim under the Equal Pay Act. Accordingly, Defendants’ motion to dismiss (Dkt. 14) is granted in part and denied in part. Count III is dismissed without prejudice and with leave to replead. Defendants’ motion to dismiss

is otherwise denied. If and when Plaintiff files an amended complaint, the Court will order expedited and targeted discovery into the lack of timeliness issue. I. BACKGROUND

Plaintiff Anne Morehouse is a woman and former employee of Defendants. (Dkt. 12 ¶ 1.)1 Plaintiff began working for Defendants in 2006. (Id.) The last position Plaintiff held with the Illinois Central Railroad Company (which is a subsidiary of Canadian National Railway Company) was Superintendent of Positive Train Control. (Id. ¶ 4.) Until Plaintiff’s termination in 2019, Plaintiff alleges she “performed her job duties at or above [Defendants’] reasonable expectations.” (Id.) Despite her satisfactory performance, Plaintiff alleges that “less qualified male employees received more favorable treatment than female employees, including . . . receiving promotions and compensation that were denied to female employees . . . [,] receiving earned bonuses and other compensation if they left Defendants employ to work for a

competitor, and not receiving discipline for infractions for which female employees were disciplined.” (Id. ¶ 3.) Plaintiff alleges that Defendants treated male employees who were “less qualified” and had “less experience” than Plaintiff more favorably than her. (Id. ¶ 10.)

1 The Complaint is confusingly numbered. For clarity, unless otherwise specified, citations to paragraphs from the Complaint begin under the section of the Complaint entitled, “PLAINTIFF’S EMPLOYMENT WITH DEFENDANT.” (Dkt. 12 at 2.) Plaintiff alleges that, throughout this time, Defendants would not discipline males for mistakes they made in the “ordinary course of performing their job duties.” (Id. ¶ 11.) At the same time, Plaintiff alleges that females were disciplined for such

infractions. (Id. ¶ 3.) Plaintiff also alleges that males enjoyed “more favorable terms and conditions” than females. (Id. ¶ 12.) Plaintiff further alleges that she engaged in a protected activity by complaining of sexual harassment and gender discrimination in the workplace. (Id. ¶ 22.) Plaintiff alleges that co-workers who “did not complain about sexual harassment and/or gender discrimination” were not retaliated against. (Id. ¶ 23.) For example, Plaintiff alleges that after she filed the charge of discrimination preceding

this case, Defendants denied Plaintiff “employee benefits [that] are consistently awarded to employees who do not complain” of harassment or file charges of discrimination. (Id. ¶ 23.) Plaintiff contends that the reason she was terminated was because of these complaints. (Id. ¶ 25.) Plaintiff also had issues with compensation. (Id. ¶¶ 26–29.) Plaintiff contends that, despite meeting all reasonable expectations with performance, she “received

lower wages and compensation than her male colleagues despite working positions that required the same skill, effort, and responsibilities as her male colleagues.” (Id. ¶ 27.) Plaintiff also alleges that these jobs “were performed under similar working conditions.” (Id.) Plaintiff contends the disparity between her wages and the compensation of her male peers was a “willful and intentional” violation of the Equal Pay Act. (Id. ¶ 28.) Plaintiff was terminated on May 9, 2019. (Id. ¶ 5.) On June 8, 2019, Plaintiff filed a charge with the Equal Employment Opportunity Commission (“EEOC”) alleging that she had been discriminated against based on her sex, and in retaliation

for engaging in a protected activity. (Dkt. 12-1.) Plaintiff was mailed a copy of the right to sue letter, which is postmarked March 22, 2021. (Dkt. 12-2.)2 Despite the postmark, Plaintiff pleads that she received the letter through counsel on May 8, 2021. (Dkt. 12 at 2.)3 On August 6, 2021, Plaintiff filed a three-count Complaint in this Court. (Dkt. 1.) Plaintiff later filed an amended three-count Complaint on January 6, 2022. (Dkt. 12.) Count I of the Complaint alleges that Defendants violated Title VII through discrimination based on sex. (Dkt. 12 ¶¶ 6–15.) Count II alleges

that Defendants violated Title VII through retaliation for engaging in a protected activity, notably, complaining of sexual harassment and gender discrimination in the workplace. (Id. ¶¶ 16–25.) Finally, Count III alleges that the Defendants violated the Equal Pay Act of 1963, as amended, 29 U.S.C. § 206(d). (Id. ¶¶ 26–29.) Defendants move to dismiss the Complaint under Rule 12(b)(6) of the Federal Rules of Civil Procedure. (Dkt. 14.) Defendants argue that Plaintiff’s Title VII claims

are untimely and warrant dismissal. (Id. at 1.) Defendants also argue that Plaintiff’s

2 The envelope also appears to contain a handwritten date marked “5/8/2021” followed by a signature or initial. (Dkt. 12-2 at 2.) 3 Defendants contest this date. Through an affidavit and accompanying materials (Dkt. 16), Defendants contend that Plaintiff received a right to sue letter from the EEOC by email on March 23, 2021. (Dkt. 16-1 at 2.) Plaintiff’s counsel responds with an affidavit of her own which states that counsel received the letter on May 8, 2021, dated and initialed the envelope, and did not receive prior communication from the EOOC regarding the notice. (Dkt. 21-1.) For the reasons described below, none of these materials can be considered at the motion to dismiss stage. Accordingly, the Court does not consider these documents in determining the sufficiency of Plaintiff’s complaint. Equal Pay Act claim fails to state a viable cause of action and should be dismissed. (Id.) II. LEGAL STANDARD

A motion under Rule 12(b)(6) “challenges the sufficiency of the complaint to state a claim upon which relief may be granted.” Hallinan v. Fraternal Ord. of Police of Chi. Lodge No. 7, 570 F.3d 811, 820 (7th Cir. 2009). Each complaint “must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’ ” Ashcroft v. Iqbal, 556 U.S. 662

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