Woodall Wilson v. Moss Holding

CourtDistrict Court, N.D. Illinois
DecidedMarch 24, 2025
Docket1:23-cv-00091
StatusUnknown

This text of Woodall Wilson v. Moss Holding (Woodall Wilson v. Moss Holding) 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
Woodall Wilson v. Moss Holding, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION STEPHANIE L. WOODALL WILSON, ) ) Plaintiff, ) ) v. ) No. 23 C 00091 ) MOSS HOLDING and JASON POPP Judge John J. Tharp, Jr. ) ) Defendants. )

ORDER For the reasons set forth in the accompanying statement, the defendants’ motion to dismiss [36] is granted. The Court will afford the plaintiff an opportunity to replead by April 14, 2025. Absent filing of a timely amended complaint, this case will be dismissed and judgment will be entered for the defendants. STATEMENT Plaintiff Stephanie L. Woodall Wilson brought this Title VII action against her former employer Moss Holding and former supervisor Jason Popp, alleging sex discrimination and unlawful retaliation. She claims that another employee sexually harassed her by mockingly removing a scarf she had wrapped around her waist over her jeans and that she was terminated shortly after reporting the incident to Popp and to the police. After filing, Wilson and the defendants proceeded to mediation conducted through the Illinois Department of Human Rights (IDHR). During the mediation session, Wilson verbally agreed to dismiss her lawsuit in exchange for a monetary payment. But several days later, she refused to sign a written settlement, claiming that she felt pressured to submit to its terms. The defendants moved to enforce their oral agreement with Wilson, contending that she remains contractually bound to dismiss her lawsuit under Illinois law. In the alternative, the defendants seek dismissal under Rule 12(b)(6) on the grounds that Wilson had not alleged a plausible Title VII claim. The Court declines to enforce the purported settlement agreement, finding that the defendants have not carried their burden to demonstrate that Wilson submitted knowingly and voluntarily to its terms. The Court also concludes that Moss was not sexually harassed. The Court finds, however, that Wilson has plausibly alleged that she was dismissed because she engaged in protected activity under Title VII—namely, reporting her allegations of sexual harassment to her supervisor and to the police. 1. Enforcement of the Parties’ Verbal Agreement to Settle “Issues regarding the formation, construction, and enforceability of a settlement agreement are governed by local contract law.” Pohl v. United Airlines, Inc., 213 F.3d 336, 338 (7th Cir. 2000).1 In the Title VII context, federal law further requires that any settlement must be “knowing and voluntary”—“a prerequisite that must be satisfied after the existence of a binding agreement has been established under state contract principles.” Singleton v. Amita Health (Singleton II), No. 17-cv-4514, 2018 WL 6445161, at *2 (N.D. Ill. Dec. 10, 2018), aff'd, 799 F. App’x 942 (7th Cir. 2020) (citing Dillard v. Starcon Int’l, Inc., 483 F.3d 502, 507 (7th Cir. 2007)). The Court finds no need to evaluate whether the parties’ oral agreement during mediation constitutes a valid and enforceable contract per Illinois law. Assuming that it does, the defendants still bear the burden, as the parties seeking to enforce settlement of federal discrimination claims, of demonstrating that Wilson entered the agreement knowingly and voluntarily. Pierce v. Atchison Topeka & Santa Fe Ry. Co., 110 F.3d 431, 438 (7th Cir. 1997). They have failed to meet that burden. “Whether a settlement of an employment discrimination claim was entered into ‘knowingly and voluntarily’ is determined by the ‘totality of the circumstances.’” Dillard, 483 F.3d at 507 (quoting Alexander v. Gardner–Denver Co., 415 U.S. 36 (1974)). Relevant factors include: “(1) the employee's education and business experience; (2) the employee's input in negotiating the terms of the settlement; (3) the clarity of the agreement; (4) the amount of time the employee had for deliberation before signing the agreement; (5) whether the employee actually read the release before signing it; (6) whether the employee was represented by counsel or consulted with an attorney; (7) whether the consideration given in exchange for the waiver exceeded the benefits to which the employee was already entitled by contract or law; and (8) whether the employee's release was induced by improper conduct on the defendant's part.” Baptist v. City of Kankakee, 481 F.3d 485, 491 n.3 (7th Cir. 2007) (citing Pierce v. Atchison, Topeka & Santa Fe Ry. Co., 65 F.3d 562, 571 (7th Cir. 1995)).

1 As a general matter, “[o]ral settlement agreements are enforceable under Illinois law if there is clearly an offer and acceptance of the compromise and a meeting of the minds as to the terms of the agreement.” Dillard v. Starcon Int’l, Inc., 483 F.3d 502, 507 (7th Cir. 2007) (quotation marks omitted). A “meeting of the minds” exists when the parties’ conduct “objectively indicates an agreement to the terms of the [contract], even if one or more parties did not subjectively intend to be bound.” Romano v. First Midwest Bancorp, Inc., No. 20-cv-07268, 2024 WL 1363669, at *6 (N.D. Ill. Mar. 30, 2024) (quoting Cnty. Line Nurseries & Landscaping, Inc., ex rel. Bankr. Tr. v. Glencoe Park Dist., 46 N.E.3d 925, 932 (Ill. App. Ct. 2015)). Moreover, the “simple fact” that one party later seeks to memorialize an oral agreement with a written instrument does not eliminate the contractual force of the oral agreement, so long as “the ultimate contract will be substantially based upon the same terms.” See also TRT Transp., Inc. v. Aksoy, 506 F. App’x 511, 513 (7th Cir. 2013) (quotation marks omitted). The defendants correctly note that two factors cut in their favor: the plaintiff was offered consideration to which she had no legal entitlement, and her release was not induced by improper conduct. That said, other factors pull against a finding of knowing and voluntarily consent. Wilson was not represented by counsel, did not “read the release before signing it” since the agreement was oral, possessed education (“some college”) and business experience dwarfed by that of defense counsel, and had little time to deliberate since the initial proposal and oral agreement occurred on the same afternoon. The defendants also provide no basis to conclude that Wilson had “input in negotiating the terms of the settlement.” Id. In their motion, the defendants assert that IDHR’s mediation process gave Wilson an “opportunity to communicate with the IDHR mediator and opportunity for input.” ECF No. 37 at 6. Having an “opportunity for input,” however, is less a faithful paraphrase of the second Pierce factor and more an irreducible minimum of any voluntary agreement. The proper consideration is whether the opportunity to provide input was acted upon. The defendants do not assert that Wilson exerted any influence over the agreement’s terms. And the fact that the defendants drafted every word of the follow-up written settlement does little to help their cause. The Court considers Wilson’s post-mediation conduct to be telling as well. On June 8, approximately two weeks after the oral agreement, Wilson filed a statement on the docket. See ECF No. 17.

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Woodall Wilson v. Moss Holding, Counsel Stack Legal Research, https://law.counselstack.com/opinion/woodall-wilson-v-moss-holding-ilnd-2025.