Nealon v. Teamster Local 700

CourtDistrict Court, N.D. Illinois
DecidedFebruary 24, 2025
Docket1:23-cv-16487
StatusUnknown

This text of Nealon v. Teamster Local 700 (Nealon v. Teamster Local 700) 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
Nealon v. Teamster Local 700, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

JACQUETTA A. NEALON, ) ) Plaintiff, ) ) No. 23 C 16487 v. ) ) Judge Sara L. Ellis INTERNATIONAL BROTHERHOOD OF ) TEAMSTERS, LOCAL 700, ) ) Defendant. )

OPINION AND ORDER After Plaintiff Jacquetta A. Nealon resigned from her position as a correctional officer because she did not consistently get time off to observe her Sabbath, she filed this employment discrimination suit against Defendant International Brotherhood of Teamsters, Local 700 (the “Union”) alleging religious discrimination. Nealon claims that the Union violated Title VII of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. § 2000e et seq., by failing to advocate for and actively preventing her requested religious accommodation. The Union moves to dismiss for lack of subject matter jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(1), or, in the alternative, for failure to state a claim pursuant to Rule 12(b)(6). Whilie the Court finds it has subject matter jurisdiction over the case, the Court grants the Union’s motion to dismiss because Nealon has not plausibly alleged that the Union engaged in religious discrimination under any theory of liability. BACKGROUND1 Nealon belongs to a religious organization known as Israel of God. Israel of God observes the Sabbath from sundown on Friday to sundown on Saturday, as well as Biblical holidays like Passover. Nealon worked as a correctional officer in the County of Cook, Illinois, and belonged to the Union in connection with that job.2 The Union is a labor organization that

represents a bargaining unit of employees employed by the County. Among its various functions, the Union may advocate on behalf of its members for requested religious accommodations. In 2019, Nealon started requesting time off to allow her to observe the Sabbath, but the County did not honor these requests. Not only did the Union fail to advocate for Nealon’s time off requests, but it also prevented her from receiving her requested religious accommodation. Subsequently, Nealon resigned from her position in November 2021. Nealon then filed this lawsuit on December 5, 2023.

1 The Court takes the facts in the background section from Nealon’s amended complaint and presumes them to be true for the purpose of resolving the Union’s motion to dismiss. See Phillips v. Prudential Ins. Co. of Am., 714 F.3d 1017, 1019–20 (7th Cir. 2013) (Rule 12(b)); Ezekiel v. Michel, 66 F.3d 894, 897 (7th Cir. 1995) (Rule 12(b)(1)). Although the Court normally cannot consider extrinsic evidence without converting a motion to dismiss into one for summary judgment, Jackson v. Curry, 888 F.3d 259, 263 (7th Cir. 2018), the Court may consider “documents that are central to the complaint and are referred to in it” in ruling on a motion to dismiss, Williamson v. Curran, 714 F.3d 432, 436 (7th Cir. 2013). The Court “may also take judicial notice of matters of public record.” Orgone Cap. III, LLC v. Daubenspeck, 912 F.3d 1039, 1043–44 (7th Cir. 2019). The Union asks the Court to consider certain documents it attaches to its motion to dismiss. The Court addresses this request in the analysis section.

2 Nealon mistakenly refers to herself as a former employee of the Union in the amended complaint. Doc. 10 ¶ 7. However, she clarifies in her response to the motion to dismiss that she was not an employee of the Union and instead alleges religious discrimination against the Union as a labor organization under 42 U.S.C. § 2000e(e). Doc. 15 at 3. Because the parties’ briefs set forth arguments assuming the Union was either Nealon’s joint employer or a labor organization, the Court finds that Nealon’s mistake does not prejudice the Union and addresses the merits of the parties’ arguments. LEGAL STANDARD A motion to dismiss under Rule 12(b)(1) challenges the Court’s subject matter jurisdiction. Fed. R. Civ. P. 12(b)(1). The standard of review for a Rule 12(b)(1) motion to dismiss depends on whether the defendant raises a facial or factual challenge. Silha v. ACT, Inc.,

807 F.3d 169, 173 (7th Cir. 2015). If, as here, a defendant challenges the sufficiency of the allegations regarding subject matter jurisdiction—a facial challenge—the Court “must accept all well-pleaded factual allegations as true and draw all reasonable inferences” in the plaintiff’s favor. Id. “[W]hen evaluating a facial challenge to subject matter jurisdiction,” the Court employs the Twombly–Iqbal “plausibility” standard, “which is the same standard used to evaluate facial challenges to claims under Rule 12(b)(6).” Id. at 174. A motion to dismiss under Rule 12(b)(6) challenges the sufficiency of the complaint, not its merits. Fed. R. Civ. P. 12(b)(6); Gibson v. City of Chicago, 910 F.2d 1510, 1520 (7th Cir. 1990). In considering a Rule 12(b)(6) motion, the Court accepts as true all well-pleaded facts in the plaintiff’s complaint and draws all reasonable inferences from those facts in the plaintiff’s

favor. Kubiak v. City of Chicago, 810 F.3d 476, 480–81 (7th Cir. 2016). To survive a Rule 12(b)(6) motion, the complaint must assert a facially plausible claim and provide fair notice to the defendant of the claim’s basis. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007); Adams v. City of Indianapolis, 742 F.3d 720, 728–29 (7th Cir. 2014). A claim is facially plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. ANALYSIS I. Illinois Labor Relations Board Proceeding The Union argues that Nealon cannot bring her Title VII claim against it because Nealon previously filed a charge with the Illinois Labor Relations Board (“ILRB”) alleging unfair labor

practices within the meaning of the Illinois Public Labor Relations Act (“IPLRA”), 5 Ill. Comp. Stat. 315/11 (2014), which the ILRB dismissed. The Union raises two arguments involving this previous proceeding. First, the Union argues that this Court does not have subject matter jurisdiction because the ILRB “has exclusive jurisdiction to hear unfair labor practice grievances—including breach of a union’s duty of fair representation—of Illinois public employees like [Nealon].” Doc. 14 at 12. Second, the Union argues that the ILRB’s dismissal of Nealon’s unfair labor practices charge precludes this suit. The Court addresses each argument in turn. The Union first challenges this Court’s subject matter jurisdiction over Nealon’s claim. In support, the Union cites cases that describe the ILRB’s exclusive jurisdiction to hear unfair

labor practice grievances and claims alleging breach of the duty of fair representation brought by public employees. See Carver v. Nall, 172 F.3d 513, 516 (7th Cir. 1999); Stahulak v.

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Nealon v. Teamster Local 700, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nealon-v-teamster-local-700-ilnd-2025.