Jared Beatty v. Olin Corporation
34 I.E.R. Cas. (BNA) 454
7th Cir.2012Background
- Beatty injured his back at Olin in Sept. 2007; medical department initially directed a no-work period, with later retroactive notes.
- Beatty failed to consistently report to work or call in for several weeks, triggering Olin’s attendance policy.
- Olin terminated Beatty for unexcused absences under the policy, based on information from a plant clerk, without evidence of awareness of Beatty’s injury or WC status.
- Beatty later settled a workers’ compensation claim against Olin and filed a retaliatory-discharge suit under Illinois law.
- The district court granted summary judgment for Olin; the Seventh Circuit affirmed, holding no triable causation evidence that Beatty was discharged for exercising WC rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Beatty’s discharge causally related to exercising WC rights? | Beatty argues discharge was retaliation for WC claim. | Olin asserts termination based on attendance violation, not WC rights. | No genuine causation issue; termination based on policy violation. |
| Did the evidence show a retaliatory motive by Moore? | Moore knew of Beatty’s injury/claim and acted with retaliation. | Moore lacked knowledge of medical status; acted on attendance facts. | Insufficient evidence of Moore’s knowledge or motive to retaliate. |
| Does Siekierka or related Illinois cases govern here? | Employer policy could be retaliatory in effect. | Policy here was neutral and unrelated to WC; no retaliation. | Distinguished; no link between policy enforcement and WC rights. |
Key Cases Cited
- Clemons v. Mech. Devices Co., 704 N.E.2d 403 (Ill. 1998) (elements of retaliatory discharge; causation focus on employer’s motive)
- Gordon v. FedEx Freight, Inc., 674 F.3d 769 (7th Cir. 2012) (causation standard; employer’s motive required)
- Horton v. Miller Chem. Co., 776 F.2d 1351 (7th Cir. 1985) (employer acts on incomplete information not retaliation)
- Siekierka v. United Steel Deck, Inc., 868 N.E.2d 374 (Ill. App. Ct. 2007) (neutral policy possibly retaliatory; distinguishable fact pattern)
- Grabs v. Safeway, Inc., 917 N.E.2d 122 (Ill. App. Ct. 2009) (disputed medical opinions; only the WC commission can resolve)