The Bill passed in the House on March 22 and was sent to the Senate that day.
House Bill 2747 amends 5 ILCS 140/3 to allow written Freedom of Information Act (FOIA) requests to be submitted to a public body by electronic mail. It further requires each public body to post an email address where requests for public records may be directed.
The Bill passed in the House on March 22 and was sent to the Senate that day.
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On March 29, 2013, the Seventh Circuit ruled in Hall v. City of Chicago, No. 11-3279. The Seventh Circuit reversed and remanded, holding that the district court erred in granting the employer’s motion for summary judgment in Title VII.
The employee presented evidence of both objective and subjective hostile work environment where the supervisor: (1) isolated the employee from the otherwise predominantly male workforce; (2) assigned her only menial jobs; and (3) subjected her to periodic episodes of verbal intimidation (including an occasion where the supervisor indicated that he “ought to slap that woman,”) which suggested that his animus was related to her gender. The fact that each action individually was insufficient by itself to establish hostile work environment did not require a different result. On April 15, 2013, Antoinette Choate spoke on employment law (focusing on employee rights) at Harold Washington Library as part of a joint program with the Chicago Public Library and the Chicago Bar Association.
The Law at the Library program is designed to offer free legal information on today’s hot legal issues. Each Law at the Library program features a presentation by an experienced attorney, followed by a brief question-and-answer session. The Illinois Appellate Court reversed and remanded the lower court in Soto v. The Board of Fire and Police Commissioners of the City of St. Charles, Illinois, 2013 IL App (2d) 120677 (March 21, 2013).
The Court held that where there could be multiple bases for a Board's decision to not hire an applicant, but no findings were made, remand to issue findings is appropriate. The court must determine whether the Board relied on improper factors in making its employment decision, or whether its decision was against the manifest weight of the evidence, not merely identify in the record reasons that could justify the Board's decision where such findings have not been made. On March 21, 2013, the Seventh Circuit ruled in Northington v. H & M International, No. 12-1233, a Title VII case alleging that plaintiff was fired in retaliation for making a complaint that co-workers harassed plaintiff.
The Seventh Circuit held that the District Court did not err in granting employer’s motion for summary judgment. The Seventh Circuit noted that the employee did not state at the time of the complaint that co-workers harassment of the employee was based on any protected classification. Furthermore, the record established that the motivation for the harassment was based only on personal conflict between the plaintiff and her co-workers. As such, plaintiff failed to show that she had engaged in protected activity to support retaliation claim. |
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