Brame v. City of North Chicago, 353 Ill. Dec. 458

Brame, a lieutenant in the North Chicago police, sued under Whistleblower Act §15(b) alleging retaliation for disclosing suspected criminal activity by the police chief to the mayor.
Defendants moved for summary judgment, arguing the Act does not cover disclosures to one's own government or law-enforcement employer and there is no individual liability.
Trial court granted summary judgment; on appeal, Brame argues section 15(b) protects disclosures to his own government employer when that employer is a government or law-enforcement agency.
Court held the Act’s plain language protects such disclosures and no exception applies if the employer is a government or law-enforcement agency.
Issues remain as to whether Brame had a reasonable belief of a crime and whether his shift change was retaliation, so summary judgment was inappropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 15(b) protect disclosures to one's own government/law-enforcement employer?	Brame argues the Act covers disclosures to his own government employer.	City argues reporting to one's own governmental employer is not protected by the Act.	Yes; plain language supports protection.
Are there genuine issues of material fact regarding reasonable belief of crime?	Belief and disclosure were reasonable under the Act.	Undisputed facts negate a reasonable belief.	Issues remain; not decided as a matter of law.
Is a midnight shift change actionable retaliation under the Act?	Shift changes can constitute retaliation.	Shift changes cannot be retaliation as a matter of law.	Not decided; remanded for further proceedings.

Mydlach v. DaimlerChrysler Corp., 226 Ill.2d 307 (Ill. 2007) (de novo review of summary judgment standard applied)
Weather-Tite, Inc. v. University of St. Francis, 233 Ill.2d 385 (Ill. 2009) (statutory construction; plain meaning governs)
Gerwin v. Livingston County Board, 345 Ill.App.3d 352 (Ill. App. 2003) (reasonableness of belief generally a question of fact)