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Crawford v. American Coal Co.

March 11, 2008

CHRISTOPHER CRAWFORD, PLAINTIFF,
v.
AMERICAN COAL COMPANY, DEFENDANT.



The opinion of the court was delivered by: Reagan, District Judge

MEMORANDUM AND ORDER

A. Introduction

Sued in Illinois state court by an employee who was injured in the job, American Coal Company removed the action to this United States District Court, where -- after soliciting and reviewing jurisdictional briefs -- the undersigned Judge determined that subject matter jurisdiction lay under the federal diversity statute. See Docs. 9-11. The case is set for trial April 14, 2008, with a final pretrial conference March 28, 2008.

Now before the Court is American Coal's January 4, 2008 motion for summary judgment, which was fully briefed as of February 25, 2008 (see Docs. 36, 38, 41, 42 and 43). For the reasons explained below, the Court now grants that motion.

B. Analysis

Christopher Crawford worked for American Coal Company in its Galatia mine. In late June 2005, Crawford slipped and fell while working underground at the mine's "Millenium Portal."

Several days later, after being examined by a physician who released him to return to light duty assignment at the mine, Crawford was discovered sleeping on the job. He was immediately terminated. Crawford sued American Coal in the Circuit Court of Saline County, Illinois, claiming that he was fired in retaliation for asserting rights under the Illinois Workers' Compensation Act.

American Coal timely removed the action to this federal district court, invoking subject matter jurisdiction under 28 U.S.C. § 1332. The undersigned District Judge determined that all prerequisites for diversity jurisdiction had been satisfied.*fn1

The case was given a firm trial date, and discovery proceeded. American Coal now seeks summary judgment in its favor on all claims under Federal Rule of Civil Procedure 56, in compliance with Local Rule 7.1 of this District. Analysis of the motion begins with reference to the governing legal standard.

Summary judgment is appropriate where there are no genuine issues of material fact, and the moving party is entitled to judgment as a matter of law. Breneisen v. Motorola, Inc., 512 F.3d 972 (7th Cir. 2008), citing Fed. R. Civ. P. 56(c), Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986), and Krieg v. Seybold, 481 F.3d 512, 516 (7th Cir. 2007). In ruling on a summary judgment motion, this Court must construe the evidence and all inferences reasonably drawn from the evidence in the light most favorable to the non-moving party. TAS Distributing Co., Inc. v. Cummins Engine Co., Inc., 491 F.3d 625, 630 (7th Cir. 2007); Reynolds v. Jamison, 488 F.3d 756, 764 (7th Cir. 2007). Thus, the undersigned Judge construes all facts and makes all reasonable inferences in favor of Crawford, the non-movant here.

Crawford claims that he was discharged in retaliation for exercising his rights under the Illinois Worker's Compensation Act, rendering his discharge "contrary to the public policy of the State of Illinois as set forth in [that] Act, 820 ILCS 305/1, et seq." (Doc 2-2, ¶ 10). In assessing Crawford's retaliatory discharge claim, one preliminary issue bears note.

The Seventh Circuit has not squarely decided "whether, under the Erie doctrine, a federal court exercising diversity jurisdiction to hear a retaliatory discharge claim under the Illinois Workers' Compensation Act must apply the Illinois framework, or whether it may use the familiar burden-shifting method" of McDonnell Douglas Corp. v. Green, 411 U.S.792 (1973). McCoy v. Maytag Corp., 495 F.3d 515, 521 (7th Cir. 2007).

Illinois courts treat a retaliatory discharge action as a traditional tort claim, and so have rejected the McDonnell Douglas analytical framework. Clemons v. Mechanical Devices Co., 704 N.E.2d 403, 407-08 (Ill. 1998); Hiatt v. Rockwell Int'l, 26 F.3d 761, 767 n.4 (7th Cir. 1994). Under Illinois' approach, to recover damages for the tort of retaliatory discharge predicated on rights under the Workers' Compensation Act, an employee must prove: (1) that he was an employee before the injury, (2) that he exercised a right granted by the Workers' Compensation Act, (3) that he was discharged, and (4) that the discharge was causally related to his filing of a claim under the Act. Clemons, 704 N.E.2d at 406, citing Gonzalez v. Prestress Engineering Corp., 551 N.E.2d 793 (Ill. App. 1990).

By contrast, federal courts hearing such claims may use McDonnell Douglas' burden-shifting approach. See Bourbon v. Kmart Corp., 223 F.3d 469, 473 (7th Cir.2000); Hiatt, 26 F.3d at 767. Under the McDonnell Douglas framework, a plaintiff can establish a prima facie case of discrimination by satisfying four elements: (1) the plaintiff was in a protected class, (2) he was meeting his employer's legitimate work expectations, (3) he suffered an adverse employment action, and (4) employees outside the protected class were treated more favorably than he. If the plaintiff makes this showing, the burden shifts to the defendant to articulate a legitimate, non-discriminatory reason for the adverse employment action. If this burden is satisfied, then the ...


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