White v. Deere & Company, 4:23-cv-04022

Daniel J. White was hired by Deere & Company to lead the Carver project, an autonomous, battery-powered tractor, in February 2022. His role was at-will.
Deere acquired Kreisel Electric, a battery manufacturer, and intended to use Kreisel’s batteries—including those with prior fire incidents—in the Carver tractor.
White regularly expressed concerns over the safety and reliability of Kreisel batteries, advocating for independent third-party testing over Deere’s preferred internal process.
There were ongoing disputes between White and his peers and supervisors about testing authority and strategy, leading to workplace friction and negative feedback regarding White’s leadership.
White was terminated after being recorded drinking beer during a work meeting; White claims the termination was actually retaliation for his safety complaints regarding Kreisel batteries.
Deere moved for summary judgment on White’s retaliatory discharge claim, alleging his discharge was for legitimate, non-retaliatory reasons.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Retaliatory Discharge (Causation)	White was fired for raising safety concerns about the Kreisel batteries.	White was terminated for poor leadership, workplace clashes, and drinking on the job.	Summary judgment denied; causation is a fact question.
Evidence of Retaliatory Motive	Circumstantial evidence (texts, timing, supervisor reaction) demonstrates improper motive.	No direct evidence of retaliatory motive, only legitimate reasons and timing.	Circumstantial evidence sufficient for jury consideration.
Materiality of HR Employee’s Role	HR’s actions and knowledge are relevant to motivation behind termination.	HR lacked technical knowledge and decisionmaking authority; irrelevant to motive.	HR’s involvement/materiality is a fact issue for the jury.
Effect of Legitimate, Non-Retaliatory Reasons	Defendant’s asserted reasons are pretextual; not the real cause for discharge.	Termination was justified for documented misconduct and team relationship failures.	Existence of legitimate reasons is insufficient for summary judgment when motive disputed.

Michael v. Precision All. Grp., 21 N.E.3d 1183 (Ill. 2014) (retaliatory discharge requirements and causation burden)
Palmateer v. Int’l Harvester Co., 421 N.E.2d 876 (Ill. 1981) (public policy exception for retaliatory discharge, including whistleblowing)
Jacobson v. Knepper & Moga, P.C., 706 N.E.2d 491 (Ill. 1998) (expanding retaliatory discharge to whistleblowing activities)
Turner v. Mem’l Med. Ctr., 911 N.E.2d 369 (Ill. 2009) (elements for Illinois retaliatory discharge)
Hartlein v. Ill. Power Co., 601 N.E.2d 720 (Ill. 1992) (pretext and valid basis for termination in retaliatory discharge)
Clemons v. Mech. Devices Co., 704 N.E.2d 403 (Ill. 1998) (Illinois rejects federal burden-shifting for retaliatory discharge)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard)