People ex rel. Department of Human Rights v. Oakridge Healthcare Center, LLC

Illinois Supreme Court
Civil Court
Employment Discrimination
Citation
Case Number: 
2020 IL 124753
Decision Date: 
Thursday, September 24, 2020
District: 
1st Dist.
Division/County: 
Cook Co.
Holding: 
Appellate court reversed; circuit court affirmed.
Justice: 
KILBRIDE

Circuit court entered judgment against long-term care facility for its discriminatory conduct against a former employee, in violation of Illinois Human Rights Act. Illinois' long-standing common-law rule of corporate successor nonliability, and not the federal successor liability doctrine, applies in cases when a judgment has been entered for a violation of Illinois Human Rights Act. The judgment was entered solely against nursing home, and the pleadings did not request relief from any other individual or entity. Thus, its corporate successor did not incur any liability for fulfilling the judgment against its predecessor, which had gone out of business 2 years prior to entry of judgment. (A. BURKE, GARMAN, KARMEIER, THEIS, and M. BURKE, concurring.)