Tibbs v. Administrative Office of the Illinois Courts, 860 F.3d 502

Autumn Tibbs was an administrative assistant in the Illinois circuit court system who took two FMLA leaves (Mar–May 2011; Jun–Aug 2012) and was suspended the day she returned from her second leave.
Judge Leslie Graves (Presiding Judge, Sangamon County) supervised Tibbs’ day‑to‑day work; Chief Judge Richard Mitchell had authority over circuit‑wide administration and ultimately discharged Tibbs after she declined to attend a disciplinary meeting.
The disciplinary letter alleged multiple instances of misconduct: changing court‑reporter assignments without authority, going over Graves’s head about returning to full time, improperly handling a vault box for a former court reporter, and making disparaging comments undermining supervisors.
Tibbs declined the offered disciplinary meeting and sent a letter stating she would not attend; after she did not respond to the allegations, Chief Judge Mitchell discharged her.
Tibbs sued the Administrative Office of the Illinois Courts for FMLA retaliation, alleging the Office was her employer and discharged her in retaliation for taking FMLA leave. The district court granted summary judgment for the Administrative Office.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Administrative Office of the Illinois Courts was Tibbs’s employer for purposes of FMLA liability	The Administrative Office employed Tibbs and thus is a proper FMLA defendant	The Administrative Office was not Tibbs’s employer and, in any event, did not make the firing decision	Court declined to decide the issue definitively; affirmed judgment without resolving employer question (not necessary to the disposition)
Whether Tibbs presented sufficient evidence of FMLA retaliation (causation/pretext)	Close temporal proximity (suspension immediately on return) plus disagreement with stated reasons support an inference of retaliation	The Administrative Office (and Chief Judge Mitchell) had facially legitimate reasons for discipline and discharge; Chief Judge Mitchell honestly believed those reasons and acted independently	Affirmed: Tibbs failed to show evidence from which a reasonable jury could infer retaliatory animus or that the proffered reasons were pretextual

Whitaker v. Wisconsin Dep’t of Health Servs., 849 F.3d 681 (7th Cir.) (summary judgment standard and treating non‑movant’s evidence as true)
Preddie v. Bartholomew Consol. Sch. Corp., 799 F.3d 806 (7th Cir.) (causation standard for FMLA retaliation)
Loudermilk v. Best Pallet Co., 636 F.3d 312 (7th Cir.) (temporal proximity sometimes supports inference of causation)
Burton v. Bd. of Regents of the Univ. of Wis. Sys., 851 F.3d 690 (7th Cir.) (pretext requires more than poor judgment; must be a phony reason)
Harden v. Marion Cnty. Sheriff’s Dep’t, 799 F.3d 857 (7th Cir.) (timing alone rarely suffices to show retaliation; need evidence of pretext)
Holman v. Indiana, 211 F.3d 399 (7th Cir.) (distinguishing proper defendant among state entities in employment suits)
Hearne v. Bd. of Educ. of the City of Chicago, 185 F.3d 770 (7th Cir.) (employer identity controls which state entities are proper defendants)
Crest Hill Land Dev., LLC v. City of Joliet, 396 F.3d 801 (7th Cir.) (judicial admissions in an answer bind the party)