Taylor v. Board of Education of the City of Chicago

2024 IL App (1st) 231373-U
CourtAppellate Court of Illinois
DecidedNovember 21, 2024
Docket1-23-1373
StatusUnpublished

This text of 2024 IL App (1st) 231373-U (Taylor v. Board of Education of the City of Chicago) 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
Taylor v. Board of Education of the City of Chicago, 2024 IL App (1st) 231373-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (1st) 231373-U Fourth Division Filed November 21, 2024 No. 1-23-1373

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT

TRUDY TAYLOR, ) ) Appeal from the Plaintiff-Appellant, Circuit Court of Cook County ) v. ) No. 2021 L 009050 ) THE BOARD OF EDUCATION OF THE ) The Honorable Patrick J. Sherlock, CITY OF CHICAGO and KAREN SAFFOLD, ) Judge, presiding. Defendants-Appellees. )

JUSTICE OCASIO delivered the judgment of the court. Presiding Justice Rochford and Justice Hoffman concurred in the judgment.

ORDER

¶1 Held: The entry of summary judgment against plaintiff, who had been discharged from her position as interim principal at an elementary school, was affirmed where she failed to show the existence of a genuine factual dispute on the merits of her claims against the school board for retaliatory discharge and against her former supervisor for tortious interference.

¶2 Plaintiff Trudy Taylor filed a two-count complaint raising claims of retaliatory discharge

in violation of public policy against her former employer, the Board of Education of the City of

Chicago (the Board), and tortious interference with prospective economic advantage against her

former supervisor, Board employee Karen Saffold. The trial court granted the defendants’ joint

motion for summary judgment, and Taylor appealed. We affirm. No. 1-23-1373

¶3 I. BACKGROUND

¶4 A. The Underlying Events

¶5 The following undisputed facts are disclosed by the record.

¶6 Taylor worked in the Chicago Public Schools (CPS) for more than 30 years as a teacher, as

an assistant principal, and then as a principal. In 2013, the school where Taylor worked as the

principal closed, and she was reassigned to duties as an interim principal for schools without a

regular principal under contract. During the summer of 2015, she was assigned to serve as interim

principal at George Washington Carver Elementary School (Carver). Before the start of the school

year, Carver was moved into a new administrative subdivision known as a “network.” The chief

of the new network was Saffold, who had previously supervised Taylor as the principal of an

elementary school where Taylor taught.

¶7 By the end of October 2015, Saffold had concluded that Taylor should be removed from

her role as interim principal of Carver. Saffold’s assessment of Taylor’s performance was set out

in a memorandum dated October 27, 2015, which concluded that Taylor “had failed to meet the

basic expectations to lead the school” and recommended “ending the assignment” and replacing

Taylor with somebody else. After consulting with Elizabeth Kirby, who supervised the network

chiefs, Saffold issued Taylor a one-page memorandum of understanding on November 4, 2015.

The memorandum of understanding identified several “[i]nstructional concerns” about Taylor’s

performance as interim principal and specified a series of “[e]xpectations moving forward” that

Saffold had for Taylor’s supervision of teachers and academics at Carver.

¶8 Around the same time that Saffold gave Taylor the memorandum of understanding, the

local school council (LSC) for Carver was interviewing candidates for the four-year contract

principal position. Taylor was one of the applicants. Taylor received six of the ten votes cast at the

LSC’s December 2015 meeting, but that fell one vote shy of the required supermajority. The LSC

referred the final decision to CPS’s chief executive officer, who delegated it to then-Chief

Education Officer Janice Jackson. Jackson, assisted by Kirby, interviewed Taylor and the second-

-2- No. 1-23-1373

place candidate. After the interviews, they recommended hiring neither candidate, and they also

recommended that Taylor be removed immediately from her position as interim principal at Carver.

The Board adopted both recommendations. Taylor was summoned to Saffold’s office on January

20, 2016, and given a notice of dismissal. Despite these adverse decisions, Taylor remained eligible

to be hired as a principal by schools in CPS, including Carver.

¶9 After Taylor was fired, she asked to meet with Kirby, for whom she had worked in the past.

Kirby agreed, and they met at Kirby’s office on February 9, 2016. What transpired during this

meeting is disputed, as discussed below.

¶ 10 B. Pleadings

¶ 11 In December 2016, Taylor filed a complaint in federal court raising a variety of claims

under both state and federal law, including the two state-law claims at issue in this appeal. Those

two claims survived a motion for summary judgment (see Fed. R. Civ. Pro. 56 (eff. Dec. 1, 2010)),

but her federal claims did not, and, in September 2020, the federal court dismissed Taylor’s

remaining state-law claims without prejudice for lack of jurisdiction.

¶ 12 Exactly 364 days later, Taylor filed the underlying two-count complaint in the circuit court

of Cook County. In general, the complaint alleged that Saffold had harbored a grudge against

Taylor since 2006 over Taylor’s vote against Saffold’s preferred candidate for an assistant

principalship at an elementary school where Taylor taught and served as a teacher representative

on the LSC. It alleged that, over the ensuing years, Saffold had tried to sabotage Taylor’s career in

various ways, eventually succeeding in getting Taylor fired from Carver. Count I of the complaint

was against the Board for retaliatory discharge against public policy. It alleged that, on February

9, 2016, Kirby disclosed to Taylor that one of the reasons she had been fired was that a clerk at

Carver had “made too much money” during summer and winter breaks in 2015. It further alleged

that the meaning of the remark was that Taylor was fired “for her activities in approving payments

to workers at Carver for services that were lawfully rendered, including payments for minimum

wage and overtime,” in accordance with the requirements of “Illinois and federal minimum and

-3- No. 1-23-1373

overtime law.” Count II of the complaint was against Saffold for tortious interference with

prospective economic advantage. It alleged that Saffold had induced the Carver LSC not to award

the four-year principal contract to Taylor by discouraging LSC members from voting for her

through intimidation and inappropriate visits to the school. It also alleged that Saffold had induced

the Board to pass over Taylor for the Carver contract and terminate her employment as interim

principal by “making unfavorable, false, and unjustified comments about Taylor’s performance”

to her superiors and by “falsely suggesting *** that Taylor had overpaid her clerk at Carver.”

¶ 13 In their answers, the Board and Saffold raised, as affirmative defenses, a variety of theories

of immunity under the Local Governmental and Governmental Employees Tort Immunity Act

(Tort Immunity Act) (745 ILCS 10/1-101 et seq. (West 2016)).

¶ 14 C. Summary Judgment

¶ 15 In April 2023, the Board and Saffold filed a joint motion for summary judgment in their

favor on Taylor’s claims, both on the merits and on their affirmative defenses of immunity. The

motion was supported by 26 exhibits, including Saffold’s affidavit, an unsworn declaration under

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