Doe v. TK Behavioral, LLC

Plaintiff filed an eight-count complaint against the defendants alleging that she was sexually abused and assaulted multiple times by an employee when plaintiff was a patient at the defendant’s treatment center. Counts VII and VIII alleged that defendants violated section 11 of the Gender Violence Act. The circuit court dismissed those two counts and entered a Rule 304(a) finding. The appellate court reversed the dismissal of counts VII and VIII, finding that plaintiff’s allegations were sufficient to plead a cause of action under section 11 of the Act for defendants’ alleged failure to reasonably supervise, train, or monitor the employee or to investigate plaintiff’s complaints against him. (MARTIN and LAMPKIN, concurring)