Navarette v. Madison County Sheriff's Office

CourtDistrict Court, S.D. Illinois
DecidedMarch 27, 2025
Docket3:17-cv-00347
StatusUnknown

This text of Navarette v. Madison County Sheriff's Office (Navarette v. Madison County Sheriff's Office) 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
Navarette v. Madison County Sheriff's Office, (S.D. Ill. 2025).

Opinion

FOR THE SOUTHERN DISTRICT OF ILLINOIS

GUSTAVO NAVARRETE,

Plaintiff,

vs. Case No. 17-cv-347-SMY

MADISON COUNTY, ILLINOIS,

Defendant.

ORDER

On April 5, 2017, Plaintiff Gustavo Navarrete filed the instant lawsuit against Madison County Sheriff’s Office. He filed an Amended Complaint on October 17, 2017, naming Madison County, Illinois as the defendant and alleging discrimination and retaliatory termination of his employment based upon his national origin in violation of Title VII of the Civil Rights Act of 1964. See 42 U.S.C. §2000e et seq.1 On June 30, 2021, a jury returned a verdict in favor of Navarrete and awarded $250,000 in compensatory damages. Currently before the Court are Plaintiff’s Motion for Equitable Relief (Doc. 122) and Petition for Attorneys’ Fees (Doc. 129). Defendant opposes both motions. The Court held an evidentiary hearing regarding Plaintiff’s Motion for Equitable Relief on August 6, 2021, and admitted various exhibits. The Court also took judicial notice of several exhibits. Back Pay Prevailing Title VII plaintiffs are “presumptively entitled to full relief.” Hutchinson v. Amateur Elec.Supply, 42 F.3d 1037, 1044 (7th Cir. 1994) citing Albemarle Paper Co. v. Moody, 422 U.S. 405, 421 (1975). Once the jury has found that there has been employment discrimination, there is then a presumption that the employee is entitled to back pay. David v. Caterpillar, Inc.,

1 Madison County Sheriff’s Department was terminated as a Defendant with the October 17, 2017 filing of the period and those which she would have earned absent discrimination by defendant.” Horn v. Duke Homes, Div. of Windsor Mobile Homes, Inc., 755 F.2d 599 ,6060 (7th Cir. 1985). Back pay covers the period from the time of firing to the date of judgment. See David, 324 F.3d at 865. Back pay is then reduced by interim earnings, “wages (or the like) earned by a discriminated upon employee in the period after his discharge but before judgment that, but for the discrimination, would not have been earned.” Chesser v. State of Ill., 895 F.2d 330, 337 (7th Cir. 1990). Defendant has the burden to show that a plaintiff has failed to mitigate his damages or that damages are in fact less than what the plaintiff asserts. Hutchison v. Amateur Elec. Supp., Inc., 42 F.3d 1037, 1044 (7th Cir. 1994). Here, Plaintiff seeks back pay of $227,820.00 for 2016 through June 11, 2021.

Defendant argues that Plaintiff’s back pay award should be reduced because he failed to mitigate his damages. The evidence shows that Plaintiff earned $63,316.98 in 2015, which was the last full year of pay that he received; Defendant ceased paying Plaintiff on January 22, 2016. The evidence further shows that at the time of his termination, Plaintiff was subject to a Collective Bargaining Agreement (“CBA”) that was in effect from December 1, 2014 until November 30, 2017. Under the CBA, as a jail officer with 5 to 10 years of experience, Plaintiff was scheduled to have a base salary of $63,059 in 2016 and $64,484 in 2017. Under a CBA Agreement in effect from December 1, 2017 until November 20, 2020, Plaintiff was scheduled to earn a base salary of $67,953 in 2018, $71,013 in 2019, and 72,608 in 2020. Because no new CBA went in effect between 2020 and

judgment in this case. Regarding interim earnings, the evidence shows that Plaintiff found employment with the National Archives and earned $8,143.67 in 2016. He earned $2,087.00 in 2016 as a self-employed translator. Then, in 2017, Plaintiff earned $19,730.35 working for the National Archives until he Plaintiff’s earned wages from the VA from 2018 until June 11, 2021 were as follows: $24,885.11 (2018); $29,115.34 (2019); $32,552.00 (2020); and $19,515.84 (2021). A discharged employee must mitigate damages by using reasonable diligence in finding other suitable employment. Graefenhain v. Pabst Brewing Co., 870 F.2d 1198, 1202 (7th Cir. 1989). To support a failure to mitigate theory, an employer “must prove both that the claimants were not reasonably diligent in seeking other employment, and that with the exercise of reasonable diligence there was a reasonable chance that the claimants might have found comparable employment.” E.E.O.C. v. Gurnee Inn Corp., 914 F.2d 815, 818 (7th Cir. 1990). Defendant argues that Plaintiff failed to mitigate his damages by failing to exercise reasonable diligence in finding

other suitable employment. Specifically, Defendant argues that Plaintiff failed to search for comparable employment, other than applying for one law enforcement position with Scott Air Force Base. Defendant’s argument that Plaintiff could have found other comparable positions or other positions wherein he would have made more income is not unsupported by the evidence. The Defendant failed to meet its burden and provide the Court with evidence that comparable law enforcement jobs that Plaintiff was qualified to hold were available during the relevant period. To the contrary, the evidence shows: Plaintiff intended on working for the Sheriff’s office until his retirement at twenty years of service (December 1, 2027); Plaintiff has been unable to find a comparable job; Plaintiff applied for numerous jobs; Plaintiff was not hired for the security job at

Scott Air Force Base; Plaintiff could not find any other jobs in the field; Plaintiff did find alternative employment in another field of work; Plaintiff started working within one week of being terminated by Defendant; Plaintiff transitioned between new jobs for better pay; and, while Plaintiff’s current job does not provide him with the same pay, duties, field of interest or career evidence, the Court will not reduce Plaintiff’s claim for lost wages for failure to mitigate. Accordingly, the Court AWARDS Plaintiff back pay in the amount of $227,820.00. Prejudgment Interest Prejudgment interest on back pay is awarded to compensate plaintiffs for the loss of the use of money. Partington v. Broyhill Furniture Industries, Inc., 999 F.2d 269, 274 (7th Cir. 1993). There is no statutory rate for prejudgment interest. Cement Div., Nat’l Gypsum Co. v. City of Milwaukee, 144 F.3d 1111, 1114 (7th Cir. 1998). Instead, the rate is to be determined by the Court with a starting point at market rate (or the average of the prime rate for the years in question). Id. The prejudgment interest accrues from the date of the loss or that the claim accrued. Am. Nat. Fire

Ins. Co. ex rel. Tabacalera Contreras Cigar Co. v. Yellow Freight Sys., Inc., 325 F.3d 924, 935 (7th Cir. 2003).2 The evidence presented shows that Plaintiff’s date of loss or the date on which his claim accrued was January 23, 2016. The Court also finds from the that the monthly Bank Prime Loan Rate published by the Federal Reserve from 2016 is reasonable.

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Navarette v. Madison County Sheriff's Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/navarette-v-madison-county-sheriffs-office-ilsd-2025.