Michael v. Precision Alliance Group, LLC, 21 N.E.3d 1183

Plaintiffs Wayne Michael, Alan Hohman, and Craig Kluemke sued Precision Alliance Group, LLC for retaliatory discharge after reporting underweight seed bags to the Illinois Department of Agriculture.
Defendant is an agricultural seed business in Nashville, Illinois that packages and ships soybean seeds in 50-pound and 2,000-pound bags.
In late 2002–early 2003, the company discovered underweight bags; inspectors found underweight bags and multiple stop-sale orders during Department investigation.
Shawn Dudley, terminated for forklift tampering, allegedly threatened retaliation if his unemployment claim affected by the weight issue; plaintiffs assisted Dudley by weighing bags and reporting underweights to Dudley and the Department.
In March 2003, Hohman was terminated for a forklift incident; Michael and Kluemke were later discharged in April 2003 as part of a broader workforce reduction, with explanations that they were not performing adequately.
Circuit court applied Maye three-part test (prima facie case, legitimate nonpretextual reason, pretext) for discrimination; appellate court reversed, focusing on a claimed causal nexus; Supreme Court reversed appellate and affirmed circuit judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether causation was proven for retaliation given the employer’s reasons	Michael argues causal link existed between reporting and discharge.	Precision asserts valid, nonpretextual reasons foreclose causation.	Causation not established; valid reason defeats retaliation claim.
Whether the circuit court erred by applying Maye nexus as causation standard	Maye nexus supported prima facie case of discrimination.	Maye nexus was improper for retaliatory discharge, not equivalent to causation.	Maye nexus does not establish causation; pretext analysis applies.
Whether the appellate court improperly treated causation as proven based on circuit’s nexus finding	Appellate court relied on nexus to prove causation.	Nexus is not causation and cannot fulfill element of retaliation.	Appellate misapplied standard; circuit decision affirmed.
Whether defendant’s reasons were nonpretextual and thus fatal to retaliation claim	Reasons may be pretextual despite nonpretextual appearance.	Reasons were legitimate and nonpretextual.	Court found reasons nonpretextual; no retaliation established.
Whether alternative proximate causes could sustain liability despite a valid reason	There can be multiple proximate causes; damages could still flow.	If a valid nonpretextual reason exists, causation fails.	No additional proximate cause shown; no liability.

Kelsay v. Motorola, Inc., 74 Ill. 2d 172 (IL 1978) (retaliatory discharge recognized as narrow exception to at-will employment)
Palmateer v. International Harvester Co., 85 Ill. 2d 124 (IL 1981) (public policy limits on discharge for reporting illegal activity)
Barr v. Kelso-Burnett Co., 106 Ill. 2d 520 (IL 1985) (causation and public policy in retaliatory discharge)
Fellhauer v. City of Geneva, 142 Ill. 2d 495 (IL 1991) (public policy and retaliatory discharge doctrine)
Clemons v. Mechanical Devices Co., 184 Ill. 2d 328 (IL 1998) (employer’s legitimate reasons do not automatically defeat retaliation; burden on plaintiff remains)
Turner v. Memorial Medical Center, 233 Ill. 2d 494 (IL 2009) (causation requires proof of employer’s motive)
Dixon Distributing Co. v. Hanover Insurance Co., 161 Ill. 2d 433 (IL 1994) (causation element in retaliatory discharge cases)