Teresa Watson v. J.C. Penney

CourtDistrict Court, S.D. Illinois
DecidedJanuary 29, 2026
Docket3:24-cv-01636
StatusUnknown

This text of Teresa Watson v. J.C. Penney (Teresa Watson v. J.C. Penney) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Teresa Watson v. J.C. Penney, (S.D. Ill. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

TERESA WATSON,

Plaintiff,

v. Case No. 24-cv-1636-JPG

J.C. PENNEY,

Defendant.

MEMORANDUM AND ORDER This matter comes before the Court on the motion of defendant JCPenney (incorrectly named in the complaint at J.C. Penney) to dismiss and to compel plaintiff Teresa Watson to pursue her claim in arbitration rather than in court (Doc. 35). Her claim, as set forth in the Amended Complaint (Doc. 11), is a claim under Title VII of the Civil Rights Act, 42 U.S.C. § 2000e et seq., for discrimination on the basis of sexual orientation when she was terminated from her employment at the JCPenney salon in Fairview Heights, Illinois. Watson responded to the motion to compel arbitration (Doc. 41), and JCPenney replied to that response (Doc. 43). She also filed another document that has been docketed as a response to various filings (Docs. 47, 48, & 49). In addition, Watson filed a motion for recruitment of counsel (Doc. 40) and motion for change of venue and for a new judge (Doc. 46). The Court addresses the ancillary motions first to pave the way for a ruling concerning arbitration. I. Motion for Recruitment of Counsel (Doc. 40) In this bare-bones motion, Watson requests an attorney to represent her in this case. Whether to assign an attorney to represent an indigent civil litigant is within the sound discretion of the district court. Pruitt v. Mote, 503 F.3d 647, 654 (7th Cir. 2007); Jackson v. Cnty. of McLean, 953 F.2d 1070, 1071 (7th Cir. 1992). There is absolutely no right to appointment of counsel in a civil case. Pruitt, 503 F.3d at 656-57. Pursuant to 28 U.S.C. § 1915(e)(1), the Court may request the assistance of counsel in an appropriate civil case where a litigant is proceeding in forma pauperis. Mallard v. U.S. District Court, 490 U.S. 296 (1989); Pruitt, 503 F.3d at 649. Local Rules 83.1(j) and 83.8(b) obligate members of the bar of this Court to accept assignments. In deciding the request for counsel, the Court should ask (1) whether the indigent plaintiff

has made a reasonable attempt to obtain counsel or has been effectively precluded from doing so and (2) whether, given the difficulty of the case, the plaintiff appears at that time to be competent to litigate it herself. Pruitt, 503 F.3d at 654-55 (citing Farmer v. Haas, 990 F.2d 319, 321-22 (7th Cir. 1993)). “[T]he question is whether the difficulty of the case—factually and legally— exceeds the particular plaintiff’s capacity as a layperson to coherently present it to the judge or jury himself.” Id. at 655. In making this inquiry, courts usually consider factors such as the plaintiff’s literacy, communication skills, educational level, litigation experience, intellectual capacity and psychological history. Id. Regardless of the Pruitt factors, the Court need not appoint counsel where there is no reasonable likelihood that the presence of counsel would alter

the outcome of the case. Id. at 660. The Court has serious doubts about whether Watson has the ability to litigate this case competently herself. Often her filings are nearly indecipherable, and she has demonstrated an inability to accomplish the simplest litigation tasks before her like service of her filings. However, Watson has not demonstrated that she has made reasonable attempts to retain counsel and has not shown that she was effectively precluded from making a diligent effort in this regard. Furthermore, as explained below, the current issue before the Court is relatively straightforward, and there is no reasonable chance that the presence of counsel would make a difference in the outcome of that issue. The Court must conserve its attorney volunteers for cases where their presence is needed to advance a potentially meritorious cause. Watson’s case is not that cause. For these reasons, the Court will deny her motion for recruitment of counsel (Doc. 40). II. Motion to Transfer Venue and Substitute Judge (Doc. 46) In this motion, Watson asks to have all of the in-court proceedings in this case occur at the East St. Louis courthouse instead of the Benton courthouse, where the undersigned judge sits.

Holding court proceedings in Benton would be a hardship for Watson because of the distance from her home. She also suggests she would like a change of judge. Unlike litigants in Illinois state courts, federal court litigants are not allowed a change of judge as a matter of right. See 735 ILCS 5/2-1001(a)(2)(i) (“Each party shall be entitled to one substitution of judge without cause as a matter of right.”). In federal court, a judge may recuse him- or herself for various reasons, as the Court has explained to Watson in an October 7, 2025, order (Doc. 30). See 28 U.S.C. §§ 144 & 455. She asserts none of those reasons here. There is no legitimate basis to change the judge in this case. Additionally, in light of the Court’s order compelling Watson to arbitrate her claims, as

explained below, there is no need to consider the location of future court hearings (Doc. 46). III. Motion to Dismiss and Compel Arbitration (Doc. 35) JCPenney asks the Court to enforce an arbitration agreement—the Binding Arbitration and Class Action, Collective Action, and Representative Claim Waiver Agreement (“Agreement”)—that Watson signed on April 6, 2023, and to dismiss this case for improper venue pursuant to Federal Rule of Civil Procedure 12(b)(3). Watson argues that she abided by the Agreement by filing a charge with the Equal Employment Opportunity Commission (“EEOC”), which the Agreement allowed her to do. She further suggests she should not be bound to the Agreement because of the environment in which she was presented with the Agreement. Finally, she questions the validity of the sworn declaration of Angelique Ponse that JCPenney submitted in support of its motion. She raises various other arguments in her effort to continue litigating in court. As a preliminary matter, the Court will consider Ponce’s sworn declaration as competent evidence of the facts of which Ponce has personal knowledge or is otherwise competent to

testify. It is of no matter that she herself may not have prepared the declaration and did not, in the content of the declaration, explain her input, if any, into the crafting of the declaration. So long as a witness swears under penalty of perjury to facts that would be admissible in Court, the Court will consider the declaration as evidence. Ponce’s declaration passes the test, so the Court will consider it. The Court also declines to consider the brief Watson filed after JCPenney’s reply brief. Such briefs are known as “sur-reply” briefs and are not accepted in any circumstances. See SDIL-LR 7.1(a)(4).1 A. Background

Watson was a stylist at the salon at JCPenney in Fairview Heights, Illinois, starting in late February/early March 2023. She is heterosexual.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Perry v. Thomas
482 U.S. 483 (Supreme Court, 1987)
Gilmer v. Interstate/Johnson Lane Corp.
500 U.S. 20 (Supreme Court, 1991)
Mastrobuono v. Shearson Lehman Hutton, Inc.
514 U.S. 52 (Supreme Court, 1995)
First Options of Chicago, Inc. v. Kaplan
514 U.S. 938 (Supreme Court, 1995)
Howsam v. Dean Witter Reynolds, Inc.
537 U.S. 79 (Supreme Court, 2002)
Buckeye Check Cashing, Inc. v. Cardegna
546 U.S. 440 (Supreme Court, 2006)
Zurich American Insurance Company v. Watts Industries
417 F.3d 682 (Seventh Circuit, 2005)
County of McHenry v. Insurance Company of the West
438 F.3d 813 (Seventh Circuit, 2006)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Halim v. Great Gatsby's Auction Gallery, Inc.
516 F.3d 557 (Seventh Circuit, 2008)
Razor v. Hyundai Motor America
854 N.E.2d 607 (Illinois Supreme Court, 2006)
Steinberg v. Chicago Medical School
371 N.E.2d 634 (Illinois Supreme Court, 1977)
Melena v. Anheuser-Busch, Inc.
847 N.E.2d 99 (Illinois Supreme Court, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
Teresa Watson v. J.C. Penney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/teresa-watson-v-jc-penney-ilsd-2026.