On November 22, 2016, the Illinois Appellate Court, Fourth District, reversed a jury verdict in favor of a plaintiff after a jury trial on her employment discrimination claims under the Illinois Human Rights Act. Schnitker v. Springfield Urban League, Inc., 2016 IL App (4th) 150991 (11/22/2016). The plaintiff alleged that the defendant violated the Illinois Human Rights Act by failing to rehire her for a teaching position on account of her race (Caucasian) and religion (non-Pentecostal). She prevailed in a jury trial, at the conclusion of which she was awarded $100,000 in damages. The defendant appealed on the ground that the plaintiff’s jury instructions inaccurately stated the law by not requiring the plaintiff to prove causation. The appellate court agreed.
The Illinois Human Rights Act prohibits Illinois employers from discriminating against employees or job applicants based on a variety of protected classifications. Illinois courts analyze Illinois Human Rights Act employment discrimination cases under U.S. Supreme Court and 7th Circuit decisions interpreting Title VII of the Civil Rights Act of 1964, which establish a fairly straightforward proof paradigm for employment discrimination cases. Nonetheless, the jury instructions in this case, which were disputed, created reversible error. The appellate court concluded that the plaintiff was required to prove a causal link between her race or religion and the defendant’s decision to not rehire her, but her jury instructions omitted the necessity of proving causation. Therefore, the trial court erred by accepting the plaintiff’s jury instructions, which prejudiced the defendant; and the appellate court reversed and remanded the case for further proceedings.