2026 IL App (1st) 251402-U
FIRST DIVISION
August 24, 2026
No. 1-25-1402
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 JUDICIAL DISTRICT
______________________________________________________________________________
KRISTEN WOOTEN, an Individual, )
)
Petitioner-Appellant, )
)
v. )
) Petition for Review of an Order ILLINOIS EDUCATIONAL LABOR RELATIONS ) of the Illinois Educational BOARD, an Agency of the State of Illinois; VICTOR E. ) Labor Relations Board BLACKWELL, in his Official Capacity as Executive ) Director of the Illinois Educational Labor Relations ) No. 2025-CA-0012-C Board; BOARD OF EDUCATION OF BREMEN ) COMMUNITY HIGH SCHOOL DISTRICT NO. 228; ) and BREMEN COMMUNITY HIGH SCHOOL ) DISTRICT NO. 228, an Illinois unit of local government ) and school district and its Governing Board; )
Respondents-Appellees.
JUSTICE HOWSE delivered the judgment of the court.
Presiding Justice Fitzgerald Smith and Justice Cobbs concurred in the judgment.
ORDER
¶1 Held: We affirm the IELRB’s dismissal of petitioner’s unfair labor practices charge. The March 7 meeting was not an investigatory interview, and petitioner did not request union representation. Additionally, the IELRB did not err in its conclusion that petitioner was not engaged in concerted activity under the Interboro doctrine, and there is no evidence
2
to support petitioner’s claims that either the District or the Board acted with anti-union animus or retaliated against her for engaging in protected activities.
¶2 Following the termination of her employment as a teacher at Tinley Park High School (Tinley Park), petitioner Kristen Wooten filed an unfair labor practices charge pursuant to the Illinois Educational Labor Relations Act (IELRA) (115 ILCS 5/1 et seq. (West 2024)) with respondent Illinois Educational Labor Relations Board (IELRB) against respondent Bremen Community High School District 228 (District). She alleged that the District violated section 14(a) of the IELRA (Id. § 14(a) (West 2024)). Respondent Executive Director Victor E. Blackwell (Director) issued a recommended decision and order (ERDO) dismissing her charge, and the IELRB affirmed. Petitioner filed a petition for direct administrative review of the IELRB’s decision with this court under section 16 of the IELRA (Id. § 16(a) (West 2024)).
¶3 On appeal, petitioner contends that the IELRB abused its discretion by dismissing her unfair labor practices charge. Specifically, she argues that the District and respondent Board of Education of the Bremen Community High School District No. 228 (Board) violated sections 14(a)(1) and 14(a)(3) of the IELRA by infringing on her Weingarten rights (National Labor Relations Board v. Weingarten, 420 U.S. 251 (1975)), violating the Interboro doctrine (National Labor Relations Board v. Interboro Contractors, Inc., 432 F.2d 854 (2d Cir. 1970)), and retaliating against her for engaging in protected activity. For the following reasons, we affirm.
¶4 BACKGROUND
¶5 Petitioner was a first‑year probationary teacher at Tinley Park during the 2023–2024 school year. The governing collective‑bargaining agreement (CBA) required teachers to report to the building 15 minutes before the school day but did not specify when they must be inside their classrooms. Throughout the school day, classroom doors were kept shut and locked to ensure the safety of students and staff. Petitioner’s first class was scheduled to begin at 8 a.m.
3
¶6 Administrators repeatedly observed petitioner arriving at her classroom shortly before the 8 a.m. bell, leaving students unsupervised in the hallway. Assistant Principal Steven Granat informed petitioner that she was required to be at her classroom door at 7:55 a.m. to let students in. At some point, he told petitioner a second time to be at her classroom door at 7:55 a.m. when she was tardy again.
¶7 On November 28, 2023, Granat found petitioner’s students waiting outside her classroom, so he opened the door and supervised them until her arrival. For a third time, Granat impressed upon petitioner the need to be in her classroom at 7:55 a.m. Later that morning at 8:10 a.m., petitioner sent Granat an email with the subject line “Sorry!” She apologized for not being consistently at her classroom door on time. She admitted that she was “usually trying to accomplish too many things at” once and had underestimated how long some tasks took to accomplish. Petitioner added that she understood “the importance of maintaining a presence in the hallway” and promised to “be there early from this point forward.”
¶8 On November 30, 2023, another teacher opened petitioner’s classroom door to allow students entry when petitioner was not present at the required time. Following this, Assistant Principal Wendy Bumphis reminded petitioner of the expectation that teachers must be in their classrooms by 7:55 a.m., reinforcing the established “7:55 a.m. rule.”
¶9 On December 20, 2023, Tinley Park operated on a modified schedule due to final exams. Petitioner was assigned to proctor a final exam scheduled to begin at 9:05 a.m. However, she did not arrive in her classroom until approximately 9:03 or 9:04 a.m. Later that day, Bumphis scheduled a meeting with petitioner and Granat “to discuss [her] continued late arrival,” stating that petitioner was “welcome” to have union representation at the meeting.
4
¶ 10 Petitioner attended the December 21, 2023, meeting (December 21 meeting) with union representative Megan Impema. Bumphis’ summary of the meeting indicates that petitioner was advised that it was her “professional responsibility” to “be at the classroom by 7:55 a.m. to allow students access to the classroom.” Impema’s notes show that petitioner “referred to contract,” and the administration “agreed” that petitioner was “always at work on time.” Impema asked for clarification on the meaning of “late,” and the administration reiterated the 7:55 a.m. rule. Petitioner said she was “initially unclear of what was being asked of her.” Ganat told petitioner to be in her classroom “before the first bell,” and petitioner said she was “clear now” and would “do so.” Impema’s takeaways from the meeting were that it was not disciplinary and that petitioner had “clarity” on expectations and would be punctual in the future.
¶ 11 Following the December 21 meeting, petitioner adhered to the 7:55 a.m. rule
¶ 12 On March 6, 2024, Bumphis emailed petitioner to schedule a meeting the following day. Petitioner asked, “Is there anything I should bring with me?” Bumphis responded that there was “[n]o need to bring anything.”
¶ 13 Petitioner’s narrative of the March 7, 2024, meeting (March 7 meeting) indicates that Bumphis told her that they had finished the master schedule for the next school year. There were not any sections for petitioner to teach “based on student numbers,” and she was being “let go.” Petitioner asked whether she was being transferred to another building, and Bumphis responded that the decision was not a reduction in force but a termination. Bumphis said that petitioner was “a great teacher,” but it was the building administration’s decision as to whether she was a good fit at the school. Petitioner asked if the administration thought she was a good fit, and Bumphis replied, “No, based on insubordination.” Bumphis informed petitioner that she had until the
5
following morning to decide whether to resign, since that would “look better” and petitioner would “be able to get another job” if she did so.
¶ 14 Principal Theresa Nolan spoke with petitioner in the afternoon of March 8, 2024. Petitioner’s narrative indicates that she told Nolan she was unaware of any concerns about her performance until October 2023. Nolan stated it was “negligence” for petitioner not to be at her classroom door at 7:55 a.m., apparently referring to at least one fight that had occurred between students waiting outside petitioner’s classroom during October 2023. Nolan then said that she did “not expect first-year teachers in [her] school to bring the [u]nion to a meeting.” Petitioner understood that as a reference to the December 21 meeting. Nolan stated that the meeting had occurred because of petitioner’s failure to follow a “directive,” and petitioner had been “insubordinate.”
¶ 15 On March 12, 2024, Nolan scheduled a meeting the following day with Granat, Bumphis, and Impema to discuss petitioner’s and Nolan’s March 8, 2024, conversation; Nolan invited petitioner to have union representation present. Petitioner and Impema attended with their union representatives. Nolan discussed petitioner’s complaint that the administration had been “vague” about Tinley Park’s “procedures and expectations.”
¶ 16 A letter dated March 20, 2024, informed petitioner of the Board’s decision to non-renew her employment “based on performance.”
¶ 17 Petitioner filed an unfair labor practices charge with the IELRB against the District on August 22, 2024.
¶ 18 On March 4, 2025, the Director issued an ERDO recommending that petitioner’s charge be dismissed. Relevantly, the Director found that Weingarten rights did not attach to the March 7
6
meeting and that petitioner had failed to show her termination was in retaliation for protected activity and thus violative of sections 14(a)(1) and (a)(3).
¶ 19 Petitioner timely filed her exceptions to the ERDO. Her first exception challenged the ERDO’s finding as to her Weingarten rights. Petitioner’s second exception took issue with the portions of the ERDO addressing her sections 14(a)(1) and (a)(3) claims and invoked the Interboro doctrine. Her third exception “[arose] from the first two” and insisted that her termination was in retaliation for protected activity. The District filed a response.
¶ 20 The IELRB issued its opinion and order on June 16, 2025. In relevant part, the three- member majority agreed with the Director that Weingarten rights did not attach to the March 7 meeting because it was not investigatory and that petitioner had not adequately requested union representation. The majority also agreed that the record did not show that petitioner had engaged in concerted activity or had been retaliated against for any protected activity based on anti-union animus. The IELRB dismissed petitioner’s unfair labor practices charge in full.
¶ 21 Member Steve Grossman dissented from the dismissal of petitioner’s section 14(a)(3) charge, reasoning that Nolan’s March 8, 2024, statement sufficiently evinced anti-union animus to support an unfair labor practices complaint.
¶ 22 Petitioner timely filed her petition for review of the IELRB’s order with this court.
¶ 23 ANALYSIS
¶ 24 One of the IELRA’s primary purposes is to facilitate the resolution of disputes between educational employers and employees. Coon v. Illinois Educational Labor Relations Board, 267 Ill. App. 3d 669, 671 (1994).
¶ 25 Section 15 of the IELRA empowers employees to file charges against their employers with the IELRB alleging that the employer has engaged in unfair labor practices as defined under
7
section 14 of the IELRA. 115 ILCS 5/15 (West 2022). Specifically, section 14(a)(1) prohibits employers from interfering with, restraining, or coercing employees in the exercise of their rights under the IELRA. Id. § 14(a)(1). Additionally, section 14(a)(3) bars employers from discriminating in matters of hiring, tenure, or any terms or conditions of employment for the purpose of encouraging or discouraging union membership. Id. § 14(a)(3).
¶ 26 The IELRB’s regulations delegate authority to investigate charges to the executive director. 80 Ill. Adm. Code § 1120.30(a), amended at 41 Ill. Reg. 10614 (eff. Aug. 1, 2017). If, after investigation, the director finds an issue of law or fact sufficient to warrant a hearing, he “shall” issue a complaint. Id. § 1120.30(b)(5). Alternatively, if the director concludes that no such issue of law or fact exists, the director dismisses the charge. Id. § 1120.30(b)(6). To determine whether an issue of law or fact exists, the director must “consider whether the charge states a cause of action upon which relief can be granted under the [IELRA] and whether the facts provided” during the investigation “state a prima facie case.” Id. § 1120.30(b)(5), (6).
¶ 27 A charging party may file exceptions to an executive director’s dismissal and briefs in support thereof, and a respondent may respond. Id. § 1120.30(c). When reviewing exceptions, the IELRB considers whether the executive director’s dismissal was “consistent with the [IELRA],” and whether it was an abuse of discretion. Id. If the IELRB affirms the dismissal, section 16 of the IELRA permits a charging party to file a petition for review of the IELRB’s decision directly with the appellate court. 115 ILCS 5/16(a).
¶ 28 Depending on the questions presented for review, the appellate court applies various standards of review. This court reviews questions of law de novo. Kenwood-Oakland Community Organization v. Department of Human Services, 2026 IL App (1st) 241238, ¶ 97. We defer to an agency’s factual determinations as prima facie correct and will only reverse such findings if they
8
are against the manifest weight of the evidence. Id. Mixed questions of fact and law are reviewed for clear error. Id.
¶ 29 Illinois precedent holds that a reviewing court applies the abuse of discretion standard to the IELRB’s dismissal of an unfair labor practices charge at the investigatory stage. Michels v. Illinois Labor Relations Board, 2012 IL App (4th) 110612, ¶ 45; Macomb Educational Association, IEA-NEA v. Illinois Educational Labor Relations Board, 265 Ill. App. 3d 194, 254 (1994). Under this standard, the IELRB abuses its discretion “only where its decision to dismiss the charge is clearly illogical” and “arbitrary and reached without employing conscientious judgment or when the decision is clearly against logic.” Michels, 2012 IL App (4th) 110612,
¶ 45. A petitioner must make more than a “plausible argument” to meet this standard. Id., ¶¶ 46- 47. She must demonstrate “that no reasonable person could possibly” agree with the agency’s decision. Id., ¶ 46.
¶ 30 Section 14(a)(1) and Weingarten Rights
¶ 31 On appeal, the petitioner asserts that the IELRB erred in its determination that Weingarten rights did not apply to the March 7 meeting during which she was informed she was being “let go” and was offered the option to resign.
¶ 32 Petitioner references the United States Supreme Court’s ruling in Weingarten, which interpreted section 8(a)(1) of the National Labor Relations Act (NLRA) (29 U.S.C. § 158(a)(1) (1970)) as empowering employees to request the presence of a union representative during investigatory interviews, provided the employee reasonably fears that disciplinary action may result and requests such representation. Speed District 802 v. Warning, 242 Ill. 2d 92, 115 (2011) (citing 420 U.S. at 257). The NLRA’s section 8(a)(1) is the model for section 14(a)(1) of the IELRA. Warning, 242 Ill. 2d at 115. Weingarten rights are specifically applicable to
9
investigatory interviews, defined as meetings where the employer seeks additional information regarding suspected misconduct. See ITT Lighting Fixtures, Division of ITT Corp. v. National Labor Relations Board, 719 F.2d 851, 853 (6th Cir. 1983). Relevant case law also supports the idea that federal court and NLRB rulings are persuasive when examining similar Illinois provisions. Board of Education of City of Chicago v. Illinois Educational Labor Relations Board, 2013 IL App (1st) 122447, ¶ 16 n.2. Conversely, Weingarten rights do not extend to meetings held solely to inform employees of previously made disciplinary decisions, as indicated in Jackson Hospital Corp. v. National Labor Relations Board, 647 F.3d 1137, 1142 (D.C. Cir. 2011).
¶ 33 To establish a violation of Weingarten rights, an employee must demonstrate: (1) a valid request for union representation at an investigatory interview, (2) a reasonable belief that the interview could result in disciplinary action, and (3) that the employer required attendance without allowing representation. Circus Circus Casinos, Inc. v. National Labor Relations Board, 961 F.3d 469, 477 (D.C. Cir. 2020). The request for representation must be made in a manner reasonably calculated to notify the employer of the employee’s desire for union representation. Id.
¶ 34 Petitioner contends that Weingarten rights were indeed applicable to the March 7 meeting with Bumphis. She maintains that any meeting between district administrators and teachers involving disciplinary matters should be classified as investigatory, reasoning that administrators, though lacking direct authority to terminate employment, possess the ability to recommend termination and may be motivated to gather supporting evidence for such recommendations. In addition, petitioner argues that the March 7 meeting was, in fact, investigatory in nature. She claims that Bumphis and the District utilized the meeting and
10
subsequent actions as opportunities to seek additional justification for her dismissal. This ongoing pursuit of further information, both during and after the meeting, is presented as evidence of the meeting’s investigatory character.
¶ 35 Finally, petitioner attempts to distinguish the legal authorities cited by respondents. She contends that the cases relied upon by respondents pertain to the private sector and are therefore not relevant or applicable to the circumstances faced by public-school teachers, such as herself.
¶ 36 Upon review, we find that Weingarten rights do not apply to meetings that are held solely for the purpose of informing an employee of a disciplinary decision already made. This principle is supported by the ruling in Jackson Hospital Corp., 647 F.3d at 1142, which found that the right to union representation does not extend to such meetings. Moreover, petitioner has not cited any authority suggesting that this limitation should not also apply to public-sector employees. In the absence of persuasive legal precedent to the contrary, there is no basis to overturn the IELRB’s determination that the March 7 meeting was not investigatory in nature.
¶ 37 The record on appeal confirms that the primary purpose of the March 7 meeting was to inform the petitioner of her termination. There is no evidence that Bumphis sought further information or questioned petitioner regarding suspected misconduct during the meeting. Petitioner’s account of the meeting does not indicate that Bumphis engaged in any inquiry or attempted to elicit additional details on any matter. This stands in contrast to cases such as Wendt Corp. v. National Labor Relations Board, 26 F.4th 1002, 1009 (D.C. Cir. 2022), where, after informing the employee of a disciplinary outcome, the employer invited the employee to provide a response or explanation. No such opportunity was provided in the March 7 meeting, reinforcing its non-investigatory nature.
11
¶ 38 In summary, the evidence supports the conclusion that the March 7 meeting was not investigatory, and therefore, Weingarten rights did not attach.
¶ 39 Next, we address whether petitioner affirmatively requested union representation at the March 7 meeting. The record shows that petitioner sent an email on March 6, which asked, “Is there anything I should bring with me?”
¶ 40 It is established that an employee may invoke Weingarten rights by requesting union representation in the form of a question. For example, in National Labor Relations Board v. New Jersey Bell Telephone Co., 936 F.2d 144, 148 (3d Cir. 1991), the court found that an employee sufficiently requested union representation when she asked whether “she should have a union representative present.”
¶ 41 However, petitioner’s inquiry was not specific enough to reasonably alert the District that she desired union representation at the March 7 meeting. As noted in Circus Circus Casinos, 961 F.3d at 477-78, a request for representation must be reasonably calculated to put the employer on notice. In this case, petitioner did not ask if she should bring “anyone” to the meeting, nor did she mention a union representative. As a result, the request failed to meet the threshold for invoking Weingarten rights.
¶ 42 Because petitioner cannot show that the March 7 meeting was investigatory or that she requested union representation, the IELRB did not err in finding that Weingarten rights did not attach to the March 7 meeting. We cannot say the decision to dismiss the charge is clearly “illogical” and “arbitrary” and “reached without employing conscientious judgment” or that the decision is clearly against logic. Therefore, the IELRB did not abuse its discretion in dismissing petitioner’s section 14(a)(1) charge premised on rights she did not have.
¶ 43 Section 14(a)(1) and the Interboro Doctrine
12
¶ 44 Next, petitioner contends on appeal that the IELRB erred in failing to find that the District and the Board violated sections 14(a)(1) and 14(a)(3) of the IELRA. Section 14(a)(1) concerns concerted activity while 14(a)(3) relates to union activity. Warning, 242 Ill. 2d at 112. Where alleged violations of sections 14(a)(1) and (a)(3) are based on the same conduct—here, petitioner’s termination—the section 14(a)(1) violation is derivative of the 14(a)(3) one, and section 14(a)(3)’s test applies. Id. at 112-13. To establish a prima facie violation of section 14(a)(3), and derivatively section 14(a)(1), an employee must show that (1) she was engaged in protected activity, (2) her employer was aware of that activity, and (3) she was discharged because of that activity. Id. at 113.
¶ 45 Created by the National Labor Relations Board, the Interboro doctrine stands for the proposition that an employee’s assertion of a collective-bargaining right constitutes concerted activity and is protected by the NLRA. National Labor Relations Board v. City Disposal Systems, Inc., 465 U.S. 822, 829 (1984); Board of Education of Schaumburg Community School Consolidated School District 54 v. Illinois Educational Labor Relations Board, 247 Ill. App. 3d 439, 455-56 (1993) (Schaumburg). Concerted activity must be based on an employee’s “reasonable and honest belief” that she has been asked to perform a task she is not required to perform under her CBA, and her statements or activities challenging such an assignment must be “reasonably directed toward the enforcement of a collectively[-]bargained right.” City Disposal Systems, 465 U.S. at 837. Additionally, concerted activity cannot consist of a “personal gripe;” it must address a “group concern.” Schaumburg, 247 Ill. App. 3d at 455, 458.
¶ 46 Petitioner cannot satisfy this standard. Her November 28 “Sorry!” email acknowledged the 7:55 a.m. rule and promised compliance. According to Impema’s meeting notes and Bumphis’ meeting summary, petitioner’s statements at the December 21 meeting reflected
13
confusion, not a belief that the rule violated the CBA. During the meeting, she gained “clarity” on what was expected of her, and she ultimately agreed to follow the rule.
¶ 47 Petitioner also cannot demonstrate that she was engaged in concerted activity as such activity must be undertaken for the benefit of employees as a group. Schaumburg, 247 Ill. App. 3d at 455. Even if petitioner could show that she challenged the 7:55 a.m. rule as violative of the CBA, her advocacy was only on her own behalf. The record does not suggest that petitioner “contemplated [or] promoted group action.” Id. at 458.
¶ 48 The IELRB did not err in deciding that she had not undertaken concerted activity or abuse its discretion in dismissing her section 14(a)(1) charge premised on the Interboro doctrine.
¶ 49 Section 14(a)(3)
¶ 50 Petitioner finally argues that the District and the Board were substantially motivated by anti-union animus when terminating her employment in retaliation for bringing union representation to the December 21 meeting and for challenging the 7:55 a.m. rule. She argues the IELRB’s conclusion to the contrary was against the manifest weight of the evidence.
¶ 51 We must address the District’s and the Board’s contention that petitioner did not preserve her section 14(a)(3) challenge for review because she failed to file an exception challenging the Executive Director’s 14(a)(3) decision, and her opening brief did not explicitly argue the issue. However, petitioner’s second and third exceptions challenged the portion of the ERDO addressing the section 14(a)(3) charge, the IELRB reviewed petitioner’s 14(a)(3) claims, and forfeiture is a limitation on the parties—not the court. West Bend Mutual Insurance Co. v. Krishna Schaumburg Tan, Inc., 2020 IL App (1st) 191834, ¶ 53. We therefore will review the merits of petitioner’s section 14(a)(3) claim.
14
¶ 52 As explained, an employee can establish a section 14(a)(3) violation if she can show that (1) she was engaged in union activity, (2) her employer was aware of that activity, and (3) she was discharged because of that activity. Warning, 242 Ill. 2d at 113. The third element is satisfied if the union activity was a substantial or motivating factor for the employee’s discharge. Id.
¶ 53 Courts can infer anti-union motivation from (1) an employer’s expressed hostility to towards unionization combined with knowledge of the employee’s union activities, (2) proximity in time between union activities and discipline, (3) disparate treatment of employees or a pattern of targeting employees supportive of the union, (4) inconsistencies between the given reason for discipline and the employer’s other actions, and (5) shifting explanations for the discipline. City of Burbank v. Illinois State Labor Relations Board, 128 Ill. 2d 335, 346 (1989). Because an employer’s motivation is a factual question, we will only reverse the IELRB’s finding if it is against the manifest weight of the evidence. Id. at 345. A finding is against the manifest weight of the evidence if the opposite conclusion is clearly evident. Cook County School District 130 v. Illinois Educational Labor Relations Board, 2021 IL App (1st) 200909, ¶ 24.
¶ 54 Petitioner asserts that the District provided shifting explanations for her termination because they did not discipline her for her tardiness after the December 21 meeting but terminated her employment based on tardiness in March 2024. Petitioner additionally contends that that her termination for “insubordination” shows that there was a pattern of retaliating against employees who supported the union or relied on their CBA rights. Petitioner further argues that Nolan’s March 8, 2024, statement that Nolan did not expect first-year teachers to bring union representation to meetings evinced anti-union animus.
15
¶ 55 We do not find petitioner’s arguments persuasive. “Shifting explanations” are present when an employer provides inconsistent reasons for the disciplinary action. See National Labor Relations Board v. Dorothy Shamrock Coal Co., 833 F.2d 1263, 1268 (7th Cir. 1987) (the employer initially blamed the employees’ terminations on their failure to complete certain forms; later the employer admitted that most of the employees had completed the forms and stated that they had been terminated due to loss of business). The District and the Board gave petitioner a consistent reason for her termination: insubordination based on her tardiness.
¶ 56 A “pattern” of targeting union employees can be found where an employer has taken disciplinary actions against multiple employees. See Eisenberg for and on Behalf of the National Labor Relations Board v. Wellington Hall Nursing Home, Inc., 651 F.2d 902, 905 (3d Cir. 1981) (the eight discharged employees were active union supporters). Petitioner’s termination was one disciplinary action against one employee. Finally, Nolan’s statement was too isolated and ambiguous to support an inference of anti-union animus, especially considering Bumphis’s and Nolan’s invitations to bring union representation to the December 21 and March 13 meetings, respectively. National Labor Relations Board v. Stor-Rite Metal Products, Inc., 856 F.2d 957, 965 (7th Cir. 1988) (a supervisor’s isolated comments that lacked threats or promises did not support an inference of anti-union motivation when little other evidence of improper motive was present).
¶ 57 The IELRB’s conclusion that petitioner’s termination was not substantially motivated by anti-union animus was not against the manifest weight of the evidence. Therefore, the IELRB did not err in dismissing her section 14(a)(3) charge.
¶ 58 CONCLUSION
¶ 59 For the foregoing reasons, we affirm the IELRB’s decision.
16
¶ 60 Affirmed.