Purchase v. Shawnee Community College

2021 IL App (5th) 190296-U
CourtAppellate Court of Illinois
DecidedNovember 5, 2021
Docket5-19-0296
StatusUnpublished
Cited by1 cases

This text of 2021 IL App (5th) 190296-U (Purchase v. Shawnee Community College) 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
Purchase v. Shawnee Community College, 2021 IL App (5th) 190296-U (Ill. Ct. App. 2021).

Opinion

NOTICE 2021 IL App (5th) 190296-U NOTICE Decision filed 11/05/21. The This order was filed under text of this decision may be NO. 5-19-0296 Supreme Court Rule 23 and is changed or corrected prior to not precedent except in the the filing of a Petition for Rehearing or the disposition of IN THE limited circumstances allowed under Rule 23(e)(1). the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ________________________________________________________________________

KENT PURCHASE, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Pulaski County. ) v. ) No. 14-SC-58 ) SHAWNEE COMMUNITY COLLEGE, ) Honorable ) William J. Thurston, Defendant-Appellee. ) Judge, presiding. ________________________________________________________________________

JUSTICE VAUGHAN delivered the judgment of the court. Justices Barberis and Wharton concurred in the judgment.

ORDER

¶1 Held: We affirm the trial court’s grant of defendant’s motion for summary judgment where it was not required to consider an untimely filed affidavit attached to plaintiff’s motion to reconsider and there was no material issue of genuine fact.

¶2 Plaintiff appeals the trial court’s grant of defendant’s motion for summary

judgment, contending he raised a genuine issue of material fact that defendant retaliatorily

discharged plaintiff for filing workers’ compensation claims. For the following reasons,

we affirm.

1 ¶3 I. BACKGROUND

¶4 In June 2008, defendant, Shawnee Community College, hired plaintiff, Kent

Purchase, as a maintenance facilitator, which required plaintiff to perform various

maintenance jobs. Subsequently, plaintiff filed a workers’ compensation claim for an injury

sustained while working in September 2008. In December 2009, plaintiff sustained another

injury while on the job.

¶5 During all relevant times, there were three other employees in the maintenance

department, all of whom were senior to plaintiff. Don Koch, defendant’s facilities director

who supervised the maintenance department, completed evaluations of all four

maintenance employees in February 2010. Plaintiff received a lower performance score

than any other maintenance employee.

¶6 On March 16, 2010, plaintiff’s attorney sent a letter to defendant notifying it of

plaintiff’s intent to file another workers’ compensation claim for his December 2009 injury.

On March 30, 2010, defendant notified plaintiff that he was being laid off, effective June

30, 2010, due to budget cuts forcing a reduction in workforce. Plaintiff discussed the matter

with Dr. Peterson, the president of Shawnee Community College, who told plaintiff that

he would be rehired if money became available in the future.

¶7 Thereafter, plaintiff filed a complaint, in the United States District Court for the

Southern District of Illinois, asserting—in relevant part—claims under Title VII of the

Civil Rights Act (42 U.S.C. § 2000e et seq. (2012)) and retaliatory discharge. Defendant

filed a motion for summary judgment. After a hearing on defendant’s motion for summary

judgment, the Southern District granted the motion in favor of defendant because plaintiff 2 failed to establish a prima facie case of discrimination for his claims under Title VII of the

Civil Rights Act. It, however, explicitly declined to exercise supplemental jurisdiction over

plaintiff’s state law claims of retaliatory discharge.

¶8 With respect to plaintiff’s racial discrimination claim, the Southern District found

plaintiff failed to establish that the white members of the maintenance staff were similarly

situated to him where there was no evidence to support his allegation that he was far more

qualified than his coworkers based on his education and 30 years’ experience. The court

also noted:

“Even if Purchase had established his prima facie case, the College gave a

legitimate, nondiscriminatory reason for terminating him: it had to eliminate a

maintenance position, and Purchase had the least seniority and the lowest evaluation

score among the members of the maintenance staff. Purchase failed to produce

sufficient evidence showing that reason is pretext.”

¶9 Subsequently, in state court, plaintiff filed a pro se complaint of retaliatory

discharge and violation of Title VII of the Civil Rights Act (42 U.S.C. § 2000e et seq.

(2012)) against defendant, alleging defendant fired plaintiff based on his race and for filing

two workers’ compensation claims. On September 25, 2015, plaintiff, through private

counsel, filed an amended complaint, omitting plaintiff’s claims under Title VII of the Civil

Rights Act.

¶ 10 Regarding his retaliatory discharge claim, the amended complaint alleged that while

plaintiff was given a lower performance score than any other maintenance worker, an initial

termination determination occurred at defendant’s board meeting on March 1, 2010, and 3 he was not included on the termination list despite having already been evaluated. Plaintiff

alleged that the decision to terminate him occurred on March 30, 2010, only after defendant

was notified of plaintiff’s intent to file a second workers’ compensation claim.

¶ 11 Defendant filed a motion to dismiss the amended complaint, claiming the Southern

District’s order collaterally estopped plaintiff from disputing defendant had a “legitimate,

non-discriminatory reason for terminating” plaintiff. Defendant contended, as a result,

plaintiff could not prove the causation element of retaliatory discharge.

¶ 12 After a hearing on January 21, 2016, the court denied defendant’s motion to dismiss.

It reasoned:

“The racial discrimination claim in federal court is a different and separate issue

from the retaliatory discharge claim at bar,” noting that “although defendant makes

allegations that might qualify as legitimate reasons to terminate [plaintiff], they

aren’t part of the analysis, as the only issue pertinent to retaliatory discharge is

whether the determination to terminate [plaintiff] was in retaliation for filing a

worker’s compensation claim.”

It further found there were genuine issues of material fact regarding such issue.

¶ 13 Subsequently, Tiffany Ryan, defendant’s chief financial officer, and Koch were

deposed on August 18, 2017. Ryan averred that she oversaw 12 departments, including

maintenance. Ryan stated that the February 2010 evaluations were the annual college-wide

evaluations. She explained that the supervisors of each department completed the

evaluations and gave them to the vice presidents for their review.

4 ¶ 14 She averred that the State’s failure to pay defendant resulted in severe financial

issues such that defendant could not meet the demand of payroll. As a result, she and the

other vice presidents worked, for several months, on a list of people to be discharged. The

vice presidents made the list based on the suggestion of the supervisors for each

department, and defendant’s board of trustees made the ultimate decision to terminate.

Ryan clarified that there were additional people added to the initial termination list because

the financial position got worse.

¶ 15 In his deposition, Koch stated that, as a part of his job duties, he evaluated plaintiff

and the other maintenance employees. He averred that he never altered or modified any

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