The Illinois Supreme Court explained that retaliatory discharge claims are a narrow exception to general rule that employees are at-will. Precision's reason for firing one employee was because of an accident resulting from horseplay. Precision's reason for firing the other two employees was a reduction in workforce. Because the Circuit Court found Precision's reasons for firing the plaintiffs to be valid and nonpretextual, the plaintiffs did not prove element of causation.
Thus, if an employer successfully presents a nonpretexual reason for firing an employee, a plaintiff cannot meet his or her burden of proof for establishing causation in a retaliatory discharge case.