Flick v. Southern Illinois Healthcare, NFP

Illinois Appellate Court
Civil Court
Retaliatory Discharge
Citation
Case Number: 
2014 IL App (5th) 130319
Decision Date: 
Wednesday, November 5, 2014
District: 
5th Dist.
Division/County: 
Jackson Co.
Holding: 
Affirmed.
Justice: 
CHAPMAN
Medical lab director raised concerns about lab's compliance with federal regulations and shortly thereafter was presented with a severance agreement, but she did not resign and was not terminated. Two years later, lab director was again presented with severance agreement, refused to resign, and was terminated. Court properly granted Defendant's motion for summary judgment, as Plaintiff failed to present evidence establishing causal connection between her raising concerns and her termination. Plaintiff had not engaged in protected activity for nearly two years prior to her termination, and Plaintiff offered no evidence to support inference of retaliatory motive. (GOLDENHERSH and CATES, concurring.)