Shatosha Anderson v. Illinois Department of Employment Security

CourtDistrict Court, N.D. Illinois
DecidedFebruary 13, 2026
Docket1:23-cv-04097
StatusUnknown

This text of Shatosha Anderson v. Illinois Department of Employment Security (Shatosha Anderson v. Illinois Department of Employment Security) 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
Shatosha Anderson v. Illinois Department of Employment Security, (N.D. Ill. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Shatosha Anderson, Plaintiff, Case No. 1:23-cv-04097 v. Judge Mary M. Rowland Illinois Department of Employment Security, Defendant. MEMORANDUM OPINION AND ORDER Plaintiff Shatosa1 Anderson (“Anderson”) brings this action against Defendant Illinois Department of Employment Security (“IDES”) for retaliating against her in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. §2000(e) et seq. (“Title VII”) and the Age Discrimination in Employment Act, 29 U.S.C. 621 et seq. (the “ADEA”). IDES has moved for summary judgement on all claims. For the reasons stated below, IDES’ motion for summary judgment [56] is granted. SUMMARY JUDGMENT STANDARD Summary judgment is proper where “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a); see also Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). A genuine dispute as to any material fact exists if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty

1The correct spelling of Anderson’s first name is “Shatosha.” [65-1]. Lobby, Inc., 477 U.S. 242, 248 (1986). The substantive law controls which facts are material. Id. After a “properly supported motion for summary judgment is made, the adverse party ‘must set forth specific facts showing that there is a genuine issue for

trial.’” Id. at 250 (quoting Fed. R. Civ. P. 56(e)). The Court “consider[s] all of the evidence in the record in the light most favorable to the non-moving party, and [ ] draw[s] all reasonable inferences from that evidence in favor of the party opposing summary judgment.” Logan v. City of Chicago, 4 F.4th 529, 536 (7th Cir. 2021) (quotation omitted). The Court “must refrain from making credibility determinations or weighing evidence.” Viamedia, Inc. v. Comcast Corp., 951 F.3d 429, 467 (7th Cir. 2020) (citing Anderson, 477 U.S. at 255). In ruling on

summary judgment, the Court gives the non-moving party “the benefit of reasonable inferences from the evidence, but not speculative inferences in [its] favor.” White v. City of Chicago, 829 F.3d 837, 841 (7th Cir. 2016) (internal citations omitted). “The controlling question is whether a reasonable trier of fact could find in favor of the non-moving party on the evidence submitted in support of and opposition to the motion for summary judgment.” Id.

BACKGROUND A. Factual Background2 Anderson has been employed as an Auditor II with IDES since before 2021. [58] ¶ 2. As an Auditor II, Anderson is responsible for conducting audits on Illinois

2The facts are taken from IDES’ Rule 56.1 statement [58] and are undisputed unless otherwise noted. employers that are assigned to her. Id. ¶ 3. Anderson reports to audit field manager Nick Frega (“Frega”). Id. ¶ 7. Frega’s primary duty is to supervise the auditors on his team and assign those auditors audits as he receives them. Id. Frega’s supervisor is

Alexander Hogdahl (“Hogdahl”). Id. ¶ 9. Hogdahl oversees the audit program for IDES, supervises IDES field audit managers, and sets policies designed to ensure that IDES can meet audit goals set by the Department of Labor. Id. Anderson is part of IDES’ unionized workforce (“Union”), and thus the terms and conditions of her employment are covered by a collective bargaining agreement (“CBA”). Id. ¶¶ 2, 14. IDES requires Auditor IIs to meet three quantitative standard objectives: (1) complete 76 audits per year (19 per quarter), (2) complete 95% of their assigned audits

within 120 days, and (3) have 10% or less of their submitted audits returned to them for corrections. Id. ¶ 6. Though the parties disagree on whether these quantitative standard objectives were properly promulgated under the CBA and whether employees could be disciplined for failing to meet these objectives, [64] ¶ 6, it is undisputed that the objectives are measured at the end of an employee’s 12-month evaluation period, which commences on the anniversary of each employee’s date of

hire. [58] ¶ 6. As a result, not all Auditor IIs have the same annual evaluation period. Id. Before 2025, Anderson’s annual review period ran from June 1 through May 31. Id. ¶ 26. If an Auditor II fails to meet their performance objectives, their supervisor can initiate a corrective action plan (“CAP”). Id. ¶ 10. The CAP is implemented to assist an employee and is not meant to be punitive. Id. In addition, a supervisor can utilize quarterly evaluations with an auditor struggling with performance issues before and/or during a CAP time period. Id. If after a CAP, or after poor quarterly or annual evaluations, an auditor’s work performance does not improve, the supervisor can

refer the auditor to IDES’ Labor Relations Department (“Labor Relations”) for discipline. Id. ¶¶ 11, 18. Upon receiving a referral, Labor Relations, if warranted, opens a case and commences its own investigation. Id. ¶ 18. This includes collecting relevant documents, such as performance documents or time sheets, and conducting a pre- disciplinary meeting with a member of Labor Relations, the manager or supervisor of the auditor, the auditor, and a Union representative. Id. ¶¶ 18–19. Labor Relations

then presents the case to Laron Cole (“Cole”), the Chief Labor Relations Manager for IDES. Id. ¶¶ 17, 19. Cole thereafter evaluates based on the facts before him whether discipline is warranted. Id. ¶¶ 19–20. On May 19, 2021, Anderson filed with the Equal Employment Opportunity Commission (the “EEOC”) a charge of discrimination against IDES (the “May 2021 EEOC Charge”) alleging discrimination based on race, age, sex, and retaliation for

engaging in protected activity. Id. ¶ 22. On July 19, 2021, the EEOC dismissed Anderson’s charge and issued a Notice of Right to Sue letter. Id. ¶ 23. No response to the May 2021 EEOC Charge was ever required from IDES. Id. Anderson did not meet the three quantitative standard objectives in her 2021 annual evaluation. Id. ¶27. As a result, Frega placed Anderson on a 90-day CAP that commenced on July 14, 2021, id. ¶¶ 28, 29, and in October 2021 instituted quarterly, rather annual, performance reviews. Id. ¶ 31. Despite the monitoring and CAP, Anderson failed to meet any of the three quantitative standard objectives for Auditor IIs during her 2022 annual evaluation period. Id. ¶ 32.

Around September of 2022, Frega and Hogdahl referred Anderson to Labor Relations for discipline related to her poor performance. Id. ¶ 34. Labor Relations held a pre-disciplinary meeting with Anderson, her Union representative, and Frega on October 28, 2022. Id. ¶ 35. Anderson submitted a written rebuttal to the charges against her. Id. ¶ 36. After reviewing all the information presented, Cole determined that the referral to him for discipline was warranted. Id. IDES thereafter issued discipline to Anderson in the form of a one-day suspension without pay that

commenced on November 29, 2022 (the “November 2022 Suspension”). Id. ¶ 38. At the time of this suspension, neither Cole, Frega, nor Hogdahl knew that Anderson had filed her May 2021 EEOC Charge. Id.

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Shatosha Anderson v. Illinois Department of Employment Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shatosha-anderson-v-illinois-department-of-employment-security-ilnd-2026.