Williams v. Office of the Chief Judge of Cook Cnty., No. 15-2325 (7th Cir. 2016)Annotate this Case
Williams, an African-American began working for the Cook County Probation Department in 1995. In 2008, Williams reported an incident of racial intimidation. The co‐workers were counseled not to make such remarks again. In 2010, Williams reported that a supervisor was making phone calls about union matters. The supervisor was disciplined. In 2010, Williams was injured at work by a co‐worker, who yanked a door open while Williams was holding it, injuring her shoulder, and yelling, “report this too, b**ch?” She took a medical leave, filed a workers’ compensation claim, and received temporary total disability benefits. In December 2010, an independent medical evaluation determined she was capable of returning to work. No one noticed the report until June 2011. Human Resources asked her to return to work on August 2 and directed her to obtain releases, warning that failure to return to work would be considered an implied resignation. The county doctor approved her return to work, but noted that her personal physician stated that she was not able to return to work. The attorneys negotiating Williams’s disability benefits disputed the consequences of the disagreement. Williams was sent a termination letter on August 30, citing failure to communicate any intent to return to work, and the apparent expiration of her workers’ compensation benefits. The agreement ultimately reached concerning benefits listed Williams’s return to work date as September 6. Williams sued under the Illinois Workers’ Compensation and Whistleblower Acts, Title VII, and 42 U.S.C. 1981 and 1983, with breach of contract and promissory estoppel claims. The Seventh Circuit affirmed summary judgment for the defendants, finding no disputes regarding material facts.