Shalak v. City Of Chicago

CourtDistrict Court, N.D. Illinois
DecidedAugust 7, 2025
Docket1:24-cv-03941
StatusUnknown

This text of Shalak v. City Of Chicago (Shalak v. City Of Chicago) 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
Shalak v. City Of Chicago, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION OLEKSANDRA SHALAK, ) ) Plaintiff, ) v. ) Case No. 24-cv-03941 ) CITY OF CHICAGO and CHICAGO ) TREASURER, MELISSA CONYEARS- ) Judge Joan H. Lefkow ERVIN, ) Defendants. ) OPINION AND ORDER Oleksandra Shalak brings this action against the City of Chicago (the “City”) and Melissa Conyears-Ervin for terminating her employment in violation of 42 U.S.C. §§ 1981 and 1983, Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., the Americans with Disabilities Act of 1990, 42 U.S.C. § 12101 et seq., and Illinois common law. (Dkt. 11 ¶ 1.)1 Shalak brings claims of sex discrimination (Counts I and III), national origin discrimination (Counts II and IV), and race, ethnicity, and ancestry discrimination (Count V). She also alleges that defendants unlawfully retaliated against her by terminating her employment. (Counts VI, VII, VIII, and IX). Defendants move to dismiss Counts III, IV, V, VIII, and IX of Shalak’s Amended Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). (Dkt. 25.) For the reasons stated below, the court grants defendants’ motion in part and denies it in part.

1 Jurisdiction is proper under 28 U.S.C. §§ 1343(a)(2) and 1367. Venue is proper under 28 U.S.C. § 1391(b). BACKGROUND2 Shalak, a Ukrainian-born woman, began working for the City in February 2016. The City promoted her “several times and consistently awarded her merit pay raises.” (Dkt. 11 ¶ 12.) Shalak worked as an Executive Administrative Assistant from February 2016 to February 2017.

She then served as a Portfolio Manager on the Investments Team until October 2021 and became Assistant City Treasurer until her termination in April 2023. While employed with the City, Shalak’s “job performance met or exceeded … legitimate expectations.” (Id. ¶ 12.) As Assistant City Treasurer, Shalak also worked as “Director of Strategic Alliances and Partnerships” within the Diversity, Equity, and Inclusion (“DEI”) department. (Id. ¶ 13.) Shalak reported to DEI Chief Robye Scott, but City Treasurer Conyears-Ervin maintained “managerial authority and control over [Shalak’s] employment.” (Id. ¶¶ 9, 13.) From November 2021 to July 2022, Shalak suffered from pregnancy complications including severe morning sickness, deep vein thrombosis, hyperemesis gravidarum, and gestational diabetes. She notified the City’s Disability Office and asked to work from home. The

City denied this request “and then continued to … refuse to allow her to work from home through to February 2022, and only after requiring her to repeatedly … submit the same supporting medical records and information.” (Id. ¶ 19.) The City also mandated several meetings where Shalak’s “private health information was shared with others who had no legitimate reason to know.” (Id.) In March 2022, Shalak submitted a formal written complaint with the City’s Diversity and Equal Employment Opportunity Office, alleging pregnancy discrimination, disability discrimination, and failure to accommodate her disability. In July 2022, Shalak delivered her child and took leave from work pursuant to the Family and Medical Leave

2 The court only includes allegations that are relevant to defendants’ motion to dismiss. Shalak’s well- pleaded allegations are accepted as true. Chaidez v. Ford Motor Co., 937 F.3d 998, 1004 (7th Cir. 2019). Act, followed by a “disability leave of absence.” (Id. ¶ 21.) She returned to work in October 2022. In February 2023, Shalak was called into a meeting with Conyears-Ervin and Scott to discuss the Treasurer’s goals for the year. Conyears-Ervin requested that Shalak “solicit Broker-

Dealers for sponsorship money for a full day summit … put on by the Treasurer’s Office.” (Id. ¶ 24.) The Treasurer’s Office “selects and works with a number of Broker-Dealers to facilitate investment transactions.” (Id. ¶ 15.) Conyears-Ervin stated that Shalak should involve Craig Slack, Chief Investment Officer of the Treasurer’s Office, when requesting funds. Shalak replied to Conyears-Ervin that, “because the Treasurer’s Office selects Broker- Dealers to invest and manage the City’s investment portfolio,” the requested solicitations would present a conflict of interest. (Id. ¶ 25). Conyears-Ervin told Shalak that “Broker-Dealers are comfortable [making] such contributions to a Treasurer’s Office event.” (Id.) Conyears-Ervin also said that, as part of the solicitation efforts, Shalak “can use her existing relationships with Broker-Dealers from her work as part of the investments team.” (Id.¶ 24.) At the time, however,

Shalak’s job involved “very little contact or interaction with Broker-Dealers.” (Id. ¶ 27.) After her meeting with Conyears-Erwin, Shalak met Slack in his office and informed him that “she was not comfortable soliciting funds from Broker-Dealers as requested, and that she would not do it.” (Id. ¶ 28.) Slack responded that he was also uncomfortable with the request and suggested that Shalak contact Human Resources. Shalak decided not to contact HR because she knew of other Treasurer’s Office employees whom Conyears-Erwin retaliated against after they complained about similar unethical or illegal work directives. Shalak refused to perform any solicitation efforts requested by Conyears-Ervin. On April 24, 2023, Amanda Brown, the Treasurer’s Office Director of HR, notified Shalak that her position would be transferred to a new employee on April 28 and “that [Shalak] could apply for a lesser, non-comparable job in a different department that paid significantly less.” (Id. ¶ 32.) Two days later, Brown provided Shalak with a letter of resignation, but Shalak

refused to sign it or resign. On April 28, Brown emailed Shalak a termination letter, effective that day, with no reasons stated. Conyears-Ervin “made and/or approved” the decisions to transfer Shalak, present her the resignation letter, and terminate her. (Id. ¶ 36.) Defendants “have treated similarly situated male employees, non-pregnant employees, and/or employees who had not engaged in legally protected activity more favorably than [Shalak].” (Id. ¶ 37.) Indeed, defendants replaced Shalak with “one or more” such individuals. (Id. ¶ 38.) Shalak filed this action on May 14, 2024 (dkt. 1) and amended her complaint on July 21, 2024. (Dkt. 11.) LEGAL STANDARD A motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) challenges the

sufficiency of the complaint to state a claim upon which relief may be granted. The 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, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)).

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Shalak v. City Of Chicago, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shalak-v-city-of-chicago-ilnd-2025.