McGreal v. Village of Orland Park, 850 F.3d 308

Joseph McGreal, an Orland Park police officer since 2005 and union secretary, was terminated on June 28, 2010, after a sequence of internal investigations and disciplinary proceedings.
McGreal claims he was fired in retaliation for speaking at a November 2, 2009 village board meeting, where he proposed budget alternatives that would protect rank-and-file officers.
The department alleges independent, non-retaliatory grounds for discipline: a disputed October 27, 2009 traffic stop (recorded on in-car video with microphone turned off), alleged lies under oath during multiple interrogations, unauthorized high-speed pursuits, insubordinate/off-duty reckless conduct, violations of a no-contact order, and apparent obstruction of an investigation (phone-records manipulation).
McGreal was placed on paid administrative leave March 5, 2010, received a written statement listing 16 misconduct charges on April 21, 2010, and was fired after formal charges were filed; an arbitrator later sustained the termination.
McGreal sued under § 1983 (First Amendment retaliation and other claims) and state law (intentional infliction of emotional distress). The district court granted summary judgment for defendants; the Seventh Circuit affirmed.

Issue	McGreal's Argument	Defendants' Argument	Held
First Amendment retaliation — was McGreal fired for protected speech at the Nov. 2, 2009 board meeting?	McGreal: his speech was protected and motivated retaliation; timing and events show retaliatory animus.	Defendants: they lacked knowledge of his board speech and had legitimate, nonretaliatory reasons (misconduct, perjury, insubordination, obstruction) for termination.	Affirmed: McGreal failed to produce admissible evidence that defendants knew of his speech or that their proffered reasons were pretextual; summary judgment for defendants upheld.
Intentional infliction of emotional distress (IIED) — did defendants engage in extreme/outrageous conduct causing severe distress?	McGreal: investigative and disciplinary conduct caused severe emotional distress.	Defendants: conduct was not extreme/outrageous and did not cause severe distress; any distress was garden-variety.	Affirmed: McGreal produced no evidence of extreme conduct or severe distress; IIED claim fails.

Tapley v. Chambers, 840 F.3d 370 (7th Cir. 2016) (standard of review for summary judgment)
Hanover Insurance Co. v. N. Bldg. Co., 751 F.3d 788 (7th Cir. 2014) (summary-judgment standard)
Perez v. Fenoglio, 792 F.3d 768 (7th Cir. 2015) (elements for First Amendment retaliation)
Bridges v. Gilbert, 557 F.3d 541 (7th Cir. 2009) (retaliation causation framework)
Kidwell v. Eisenhauer, 679 F.3d 957 (7th Cir. 2012) (burden-shifting on causation in retaliation cases)
Greene v. Doruff, 660 F.3d 975 (7th Cir. 2011) (causation terminology and analysis)
Thayer v. Chiczewski, 705 F.3d 237 (7th Cir. 2012) (employer rebuttal and pretext analysis)
Swearnigen-El v. Cook County Sheriff's Dept., 602 F.3d 852 (7th Cir. 2010) (summary-judgment analysis in retaliation context)
Stagman v. Ryan, 176 F.3d 986 (7th Cir. 1999) (knowledge of protected speech required for causation)
Zellner v. Herrick, 639 F.3d 371 (7th Cir. 2011) (evidence required to show employer's reasons are lies)
Pugh v. City of Attica, 259 F.3d 619 (7th Cir. 2001) (timing alone insufficient to show pretext)
Loudermilk v. Best Pallet Co., 636 F.3d 312 (7th Cir. 2011) (suspicious timing is not enough to avoid summary judgment)
Zoretic v. Darge, 832 F.3d 639 (7th Cir. 2016) (elements of IIED under Illinois law)
Doe v. Calumet City, 161 Ill.2d 374 (Ill. 1994) (Illinois standard for IIED)
McGrath v. Fahey, 126 Ill.2d 78 (Ill. 1988) (garden-variety emotional distress insufficient for IIED)