French v. Jeffreys, 3:23-cv-03045

Glendal French, the plaintiff, was a correctional officer with the Illinois Department of Corrections (IDOC) who rose to the position of shift supervisor, a role protected by a collective bargaining agreement and the state Personnel Code.
Between 2018 and 2019, French temporarily served as assistant warden at Pontiac Correctional Center and was later offered a permanent assistant warden position at Western Illinois Correctional Facility.
French expressed concern about losing job security by accepting the assistant warden position, but took the job after assurances from Defendant Eilers that IDOC no longer engaged in arbitrary terminations of wardens and assistant wardens.
French was later terminated due to his involvement in an October 2018 incident involving the inappropriate distribution of a drawing at the prison. Three other supervisors received lesser penalties for greater involvement in the same incident.
French was not covered by the collective bargaining agreement at the time of his termination and alleged a due process violation based on deprivation of a property interest in his job, relying on promissory estoppel theory against IDOC and its officers.
The court reviewed the sufficiency of the complaint under Rule 12(b)(6) and ultimately dismissed French's claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Property interest in employment as assistant warden	French argued Eilers' job security assurances created a property interest via promissory estoppel, even once outside the union agreement	No mutually explicit understanding or unambiguous promise of continued employment; statements don't create a cognizable property interest	Plaintiff lacked a property interest; mere assurances did not constitute a contract or unambiguous promise
Procedural due process violation	French claimed he was deprived of his property interest in employment without notice or a hearing	No entitlement to due process where no property interest existed; firing was for cause (incident involvement)	No due process violation; no property interest, so no entitlement to procedural protections
Arbitrary firing despite lesser penalties for others	French claimed disparate treatment and that his termination was arbitrary compared to other supervisors	Plaintiff terminated for his specific involvement; actions against others irrelevant to his claim	Plaintiff failed to show firing was arbitrary or violated any promise or law
Reliance/detriment under promissory estoppel	French claimed he relied on job security assurances to his detriment by accepting the position	No actionable detriment since firing was for stated reason, not arbitrarily as promised; reliance not to plaintiff's detriment	No detrimental reliance; plaintiff did not qualify for promissory estoppel under Illinois law

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for plausibility in complaints)
Ashcroft v. Iqbal, 556 U.S. 662 (requirement for plausible claims and inferences)
Bd. of Regents v. Roth, 408 U.S. 564 (property interest in public employment requires legitimate claim of entitlement)
Perry v. Sindermann, 408 U.S. 593 (property interest may arise from mutually explicit understandings)
Quake Constr., Inc. v. American Airlines, Inc., 141 Ill.2d 281 (elements of promissory estoppel in Illinois law)