Illinois

Farrell v. S.E. Penn. Transportation Authority in Illinois Law

How Farrell v. S.E. Penn. Transportation Authority applies in Illinois: state-specific rules, key cases, and bar exam notes for Employment Law.

State Approach

Illinois courts have generally followed the reasoning established in Farrell, recognizing the importance of protecting employees from retaliatory discharge. In cases involving employment discrimination and whistleblower claims, Illinois law mirrors the concepts concerning the causation of adverse employment actions and the need for substantive justification by employers.

State Rule
In Illinois, the principle of retaliatory discharge applies in situations where an employee is terminated in retaliation for exercising rights protected by law, such as filing a worker's compensation claim or reporting unlawful acts by the employer.
Significant State Cases

Kelsay v. Motorola, Inc.

The Illinois Supreme Court held that an employee could pursue a retaliatory discharge claim for being fired after filing a worker's compensation claim.

Kujacznski v. Smith

The court upheld the rationale that a discharge in retaliation for reporting unlawful acts violates public policy, emphasizing strong protections against adverse employment actions.

Bartlett v. BNSF Railway Co.

The ruling affirmed that an employee’s whistleblowing activity is a protected activity under Illinois law, and retaliation against them is actionable.

Comparison to Federal Law

While Illinois law echoes the federal framework under laws such as Title VII of the Civil Rights Act concerning employment discrimination and retaliation, Illinois provides a more expansive definition of public policy protections. Illinois courts may allow more claims and have recognized additional categories of protected activity compared to federal statutes.

Bar Exam Note

Understanding the principles from Farrell is critical for the Illinois bar exam, particularly in the context of employment law, as it tests candidates on retaliatory discharge and public policy issues.

Practice Pointers
  • Ensure a clear understanding of what constitutes protected activity under Illinois law.
  • Gather evidence of any causal link between the protected activity and the adverse employment action.
  • Pay close attention to the employer's justification for adverse actions to assess if they are pretextual.
  • Stay updated on recent Illinois cases that expand or challenge established employment law doctrines.
  • Advise clients on the specific public policy doctrines relevant to their employment situation here in Illinois.

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