Tibbs v. Administrative Office of the Illinois Courts

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Tibbs, an administrative assistant in the Illinois court system, was suspended the day she returned to work after taking leave under the Family and Medical Leave Act, 29 U.S.C. 2601. She was then fired after she chose not to attend a disciplinary meeting. Her supervisor, a judge in the judicial circuit in which she was employed, sent a letter citing several instances of misconduct, including insubordination. Tibbs sued the Administrative Office of the Illinois Courts, contending that the agency employed her and that she was fired in retaliation for taking FMLA leave. The district court granted summary judgment for the agency, reasoning that it never employed Tibbs and thus could not have discharged her, and that in any event, there was no evidence of retaliation. The Seventh Circuit affirmed. Tibbs cannot point to evidence from which a jury could reasonably infer that any of her supervisors harbored retaliatory animus against her. The court did not resolve the question whether the Administrative Office employed Tibbs. View "Tibbs v. Administrative Office of the Illinois Courts" on Justia Law