7-28-14; To the Labors of Motherhood May Come New Civil Rights--Illinois and Federal; EEOC Issues New Guides about Rights of Pregnant Workers; IL WC Medical Fee Schedule Goes Up and much more

Synopsis: To the Labors of Motherhood May Come New Illinois Civil Rights Protections and More Challenges for Business and All Illinoisans.

 

Editor’s comment: HB 8 was hurriedly rushed through the IL House and Senate and on June 26, 2014 it was sent for Gov. Quinn’s signature. If he signs it, the bill won’t become effective until January 1, 2015. In our view, it is more unneeded regulations for Illinois business. We feel the public relations impact for our legislators to “take care of pregnant women” was too hard for them to turn down. You may note 32 legislative sponsors of this bill were women. The bill arguably promotes workplace fairness for pregnant workers by requiring employers to make reasonable accommodation for conditions related to pregnancy, childbirth, lactation and related conditions, unless the employer can demonstrate the reasonable accommodation would impose an undue hardship on the ordinary operation of the employer’s business—just as employers do for reasonable accommodations caused by other conditions.

 

What Was Wrong with Federal ADA and PDA?

 

The bill is supposedly modeled after the Americans with Disabilities Act, the Pregnancy Discrimination Act and analogous state law. We ask the rhetorical question, why not simply rely on the ADA and PDA? Proponents assert HB 8 was necessary because state and federal law and enforcement was supposedly unclear—as you will see below, the EEOC just changed their guidelines. Proponents further claim courts and employers continued to deny pregnant workers the kinds of job modifications they routinely offered to other employees who are similar in their ability or inability to work—we have no idea what rulings were being referred to. We know of one jury verdict against a well-known Chicago restaurant where a pregnant employee recovered $300,000 along with her attorney’s fees and costs for alleged employment discrimination due to pregnancy. There is no question Illinois state employment laws and federal law require employers to provide pregnant workers the same treatment and benefits provided other workers who require temporary accommodations.

 

Little Illinois Companies and Large Illinois Employers May Have to Learn and Implement This New Legislation

 

In our view, this bill may apply to your home-based nanny, cleaning lady, babysitter, dog-walker, any single person you hire to work for you. If it becomes law, the new Public Act amends the Illinois Human Rights Act and defines "pregnancy" as pregnancy, childbirth, or related conditions. It now defines an "employer" to include any person employing one or more employees when a complainant alleges civil rights violation due to unlawful discrimination based upon pregnancy. It doesn’t make a distinction between part-time or full-time workers.

 

The provisions regarding pregnancy are applicable regardless of the source of the employee's inability to work or employment classification or status, including part-time, full-time, or probationary. The bill also provides it is a civil rights violation for an employer, with respect to pregnancy, childbirth, or a related condition:

 

(1)  not to make reasonable accommodations, if so requested, unless the employer can demonstrate that the accommodation would impose an undue hardship on the ordinary operation of the business of the employer;

(2)  to deny employment opportunities or benefits to or take adverse action against an otherwise qualified job applicant or employee;

(3)  to require a job applicant or employee to accept an accommodation the applicant or employee chooses not to accept; or

(4)  to require an employee to take leave under any leave law or policy of the employer if another reasonable accommodation can be provided.

 

Can You “Misclassify” a Pregnant Worker to Try to Avoid the New Law?

 

One potential way around the new law might be to hire a “business” to provide small-scale services needed, like house-cleaning and dog-walking. What we mean by “misclassify” is to treat anyone you hire as a separate company. When you hire one person to perform a service like housekeeping, can you treat them as a “business” and issue a 1099 for payments made to them. What if the “business” you hire is a sole proprietor? We aren’t recommending creating ruses or participating in fraud to avoid the new laws—we just want our readers to better understand if you hire one worker, the new state law appears to come with employment status. On the other hand, if you hire a business to provide a service for you, the business is supposed to reasonable accommodate the pregnant worker. We have no idea is a sole proprietor of a dog-walking business has to accommodate herself if she is a business versus just a dog-walker! For larger companies, you risk the IL Department of Labor coming after you when you misclassify workers.

 

Do the Civil Rights Protections for Pregnant Workers Start When They Learn They are Pregnant and End with Childbirth?

 

No—the protections start when reasonable accommodation of pregnancy starts and end with the cessation of lactation or other medical sequalae of the pregnancy. For some mothers, this might be several years. If you aren’t sure about whether you need to accommodate at any time, send a reply and a KCB&A defense team member will give you our best thoughts.

 

Can an Illinois Business or Individual “Drug Test” to Confirm Pregnancy?

 

Some time ago, we had a client who wanted to terminate an ineffective worker—when the client talked to her worker, the troubled employee indicated she was pregnant. Our client tried to reasonably accommodate the worker for several months to then have the employee quit without notice and basically disappear. Our client felt she was bamboozled and she felt the employee completely faked her claimed pregnant status. The client asked a reasonable question—in the future, if another worker advised of pregnant status, could the client ask the employee to drug test to prove she was pregnant? It would seem reasonable under either state or federal law for documentation of status to be part of due diligence in handling all claims.

 

We have asked this question of many of our closest readers and friends and the uniform answer was not to require a pregnancy test. Instead, our readers/friends of the firm felt a much better approach was to ask the worker to provide a note from an OB-GYN or other similar physician to confirm

 

·         The fact of pregnant status and

·         The needed reasonable accommodation due to that status.

 

In taking that approach, you basically are following a much more effective model or process. You are also setting up a path for continued documentation of accommodation needs. We are happy to consider your best thoughts on this issue.

 

An IL Employer Can’t Force a Pregnant Employee to Stay Off Work

 

We know the City of Chicago sends pregnant workers in some departments home from work for a full year, whether the worker wants to work with accommodation or not. The reason you don’t hear much about this practice in the press/media is relatively few women will turn down and fight over a year off work with full pay and benefits. Both state and federal law make such practices an actual or potential violation of a pregnant worker’s civil rights. We hope City administrators stop that practice and try instead to keep hard-working employees in jobs with accommodation.

 

IL Employers Will Have to Change Your Workplace Notices and Handbooks Next Year

 

It will be a civil rights violation for an IL employer to fail to post, keep posted, or fail to include in any employee handbook information concerning an employee's rights under the Act, a notice, to be prepared or approved by the Department of Human Rights, summarizing the requirements of the Act and information pertaining to the filing of a charge, including the right to be free from unlawful discrimination and the right to certain reasonable accommodations. The bill also provides it is a civil rights violation to retaliate against a person because he or she has requested, attempted to request, used, or attempted to use a reasonable accommodation. HB 8 does not require employers to create new jobs or to fire, transfer an employee with more seniority, or promote an unqualified employee. The theory is to provide pregnant employees with reasonable, temporary accommodations to increase worker productivity, retention, and morale, decreases re-training costs, and reduces health care costs associated with pregnancy complications.

 

As we outline above, the bill was sent to the Governor on June 26, 2014. Assuming the Governor signs it and every indication is he will, the bill will become effective on January 1, 2015. If you need help implementing the new law or seek assistance with defending pregnancy claims, contact our defense team leader Brad Smith at bsmith@keefe-law.com. To read the new law, click here:

 

http://ilga.gov/legislation/billstatus.asp?DocNum=8&GAID=12&GA=98&DocTypeID=HB&LegID=68233&SessionID=85

 

We appreciate your thoughts and comments. Please post them on our award-winning blog.

 

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Synopsis: The U.S. Equal Opportunity Commission has released new guidelines for the enforcement of laws prohibiting workplace discrimination against pregnant women.

Editor’s comment: These are the first new federal guidelines on pregnancy discrimination in more than 30 years. The document, titled EEOC Enforcement Guidance on Pregnancy Discrimination Related Issues, seeks to clarify or better outline federal rules on discrimination against pregnant workers under both the Pregnancy Discrimination Act and the Americans with Disabilities Act.

The EEOC is responding to an increase in Pregnancy Discrimination charges/complaints; They also feel the Federal Courts are leaving both sides confused in their rulings

The guidelines were issued following a rising number of complaints regarding pregnancy discrimination in the workplace, as well as differing interpretations of existing law by different courts. The U.S. Supreme Court recently agreed to hear a pregnancy discrimination case during its October 2014 term, in part because of lower courts' differing views of the existing law.

New EEOC Guidelines Clarify Their View of Pregnancy Discrimination

The EEOC's new guidelines seek to make things fairly clear, emphasizing workplace discrimination against pregnant women is a prohibited form of sex discrimination. For U.S. employers and risk managers, please remember the EEOC has virtually unlimited funds and can and will sue employers over their view of what should be U.S. law. While most of these charges/claims settle, the EEOC then can force employers to accept and pay for discrimination counseling for years to come. They will also audit to insure you are complying.

Here are the important facets of the new guidelines:

Ø  Pregnancy-related conditions are considered disabilities under the ADA, which require employers to provide reasonable accommodations as they would for any other medical disability.

Ø  Employers may not fire, demote, or refuse to hire women based on a current or potential future pregnancy or any other pregnancy-related medical condition.

Ø  Lactation is a medical condition and has to be afforded "reasonable break time" to address lactation-related needs.

Ø  Women may not be forced to take leave during or following a pregnancy if they can still adequately perform their assigned tasks.

Ø  Women may not be treated differently or restricted from doing certain jobs, such as those that may expose them to hazardous chemicals, solely based on their ability to become pregnant.

Ø  An employer may not inquire about whether a woman intends to become pregnant, as such inquiries will be generally regarded as evidence of pregnancy discrimination in the event of any future unfavorable action.

The new EEOC guidelines on pregnancy discrimination take effect immediately, and can be read online in their entirety at the EEOC's websitehttp://www.eeoc.gov/laws/guidance/pregnancy_guidance.cfm

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Synopsis: The Illinois WC Commission Increases WC Fee Schedule Payment for Medical Evaluation and Management Procedures Such as Office Visits. Analysis by Pankhuri Parti, J.D.

 

Editor’s comment: While the purpose of the Order seems innocuous enough – ensuring the injured workers still have access to doctors willing to treat their work injuries, we fear the consequence of this new order may be to overburden the employers, who already face an uphill battle in the Petitioner friendly workers’ compensation system of Illinois.

 

How the IL WC Medical Fee Schedule at the Illinois Workers’ Compensation Commission Works?

 

Through the 2005-2006 Amendments of the IL WC Act, the IL legislature ordered the IL WC Commission to create fee schedules for treatment provided on or after February 1, 2006. Under this approach the payment to the medical provider would be the lesser amount of either the actual charge or the amount deemed appropriate in the fee schedule. Section 8.2 of the Workers’ Compensation Act stated clearly the fee schedule set the "maximum allowable payment;" and the employer was expected to pay to the medical provider either the actual amount billed or the fee schedule amount, whichever was less. Inherent in this approach was the liberty granted to the parties – the medical provider and the employer – to contract for amounts different than the fee schedule rates and if the contracted/billed amount was less than the fee schedule rate then the employer would be bound to pay that amount. In all these situations the amount charged, the fee schedule amount, and the contracted amount, would represent full payment for the services rendered by the medical professional.

 

It is important to note the fee schedule only affects the amount of payment made to the medical provider by the employer. It has nothing to do with the question of whether or not the treatment being undergone by Petitioner is reasonable and necessary and covered by workers’ compensation. 

 

At the time the fee schedule was first implemented the maximum allowable payment was deemed to be 90% of the 80th percentile of charges and fees as determined by the IL WC Commission and based on the information on the provider billed amounts obtained from employers’ and insurers’ national database. The Commission was then to adjust these charges by the Consumer Price Index-U or Consumer Price Index-M. As a result of the legislation the Commission established fee schedules for procedures, treatments, and services for hospital inpatient, hospital outpatient, emergency room and trauma, ambulatory surgical treatment centers, and professional services. For the services for which the fees could not be calculated, the fees were set, by default, at 76% of the charged amount.

 

Changes in the IL WC Fee Schedule System over the Years

 

On February 2009 the IL WC Commission created new fee schedules for ambulatory surgical treatment centers, hospital outpatient radiology, pathology, and laboratory, physical medicine and rehabilitation services, and surgical services, and rehabilitation hospitals. Based on its work with the Workers’ Compensation Medical Fee Advisory Board, the Commission decided the change the reimbursement methods for certain services but later repealed this changed. Instead it was decided the treatment would be paid at the 65%-of-charge rule.

 

On June 28, 2011 Governor Quinn signed the House Bill 1698 and one of the provisions in the bill reduced all fee schedules by 30% and reduced the default pay 76% of charge to pay 53.2% of charge instead. Doctors and hospitals in our state started screaming at their lobbyists over these dramatic cuts. However, many observers still feel the discounted values remained higher than group health reimbursements.

 

On July 16, 2014 the Illinois WC Commission passed an order to increase the reimbursements for certain identified services to the recommended levels so as to increase the injured employees’ access to health care.

 

The New IWCC Order and Recommended Changes

 

The Commission passed this order under Section 8.2(b) of the Act which allows the Commission to change the CPI-U if it finds there is a significant limitation on access to quality health care in either a specific field or geographical location. The order was based on a December 2013 memo which highlighted concerns about some Illinois Workers’ Compensation fee schedule payments, claiming they were at rates which might limit access to medical care. The memo raised the possibility of healthcare providers ceasing to treat injured workers where payments were unreasonably low and identified the possible reasons as the influx of millions of new insureds into the healthcare market and the Affordable Care Act.

 

The analysis on which the decision was reached compared the fee schedule amounts after the 30% reduction in September 2011 with payments made to providers under Medicare and noted fee schedule amounts for many Evaluation and Management codes were less than that provided under Medicare. Additionally, the commercial payments were significantly above those deemed as appropriate in the fee schedule. Because the commercial payments were so much higher than the fee schedule and the Medicare payments were also higher in many instances, the memo concluded there was a reasonable chance of primary care physicians ceasing to treat injured workers when they could so easily fill their schedules with better insured patients.

 

As a result the purpose of the changes was to bring the payments under the fee schedule for evaluation and management services to a level comparable to Medicare. Some of the evaluation and management procedures identified for the purposes of increasing the reimbursements rates are: office/outpatient visit new, office/outpatient visit established, home visit new patient, and home visit established patient. The order accepts the proposed CPI percentage increase, the proposed dollar increase, and the proposed fee schedule amount recommended by the memo. The IWCC memo detailing the changes can be accessed at http://www.iwcc.il.gov/EMorder.pdf

 

We appreciate your thoughts and comments. Please post them on our award-winning blog. This article was researched and written by Pankhuri Parti, J.D. She can be reached for information or assistance with this and other defense issues atpparti@keefe-law.com.

7-21-14; Confusion about Intrusion into Seclusion--When/How can Adjusters Record Statements by Joe D'Amato, JD; Matt Ignoffo Reports Great News for RUMC; Did the OD Act End for Some Workers and more

Synopsis: Can We Record or Not? Here is the Current State of Confusion for IL Claims Adjusters and Risk Managers. Analysis by Joseph F. D’Amato, J.D.

Editor’s comment: Constitutional challenges to IL eavesdropping statute leave our’ “two party consent status” up in the air. As risk managers, investigators and adjusters who regularly read this space are aware, Illinois was one of a dozen states where it was illegal to record a conversation you are having with another person (we are a so-called “two party consent” state). All parties to the conversation must agree to the recording to avoid liability in Illinois.

The statute criminalizing this behavior was known as the “eavesdropping statute.” The statute made it a crime to use an "eavesdropping device" to overhear or record a phone call or personal face-to-face conversation without the consent of all parties to the conversation. The law defined an "eavesdropping device" as "any device capable of being used to hear or record oral conversation or intercept, retain, or transcribe electronic communication whether such conversation or electronic communication is conducted in person, by telephone, or by any other means." The law made no distinction as to whether the conversation is face-to-face or over the phone. Actually, cell phones memo applications could be used in a fashion that might cause legal liability under the old legislation.

In practice, if you were investigating an alleged accident and decided to take a claimant’s or witness’s recorded statement without his or her consent, you faced a class four felony and one to three years in prison. While Illinois is in the minority of states on this issue, it is unlikely we will be for long due to two relatively recent Illinois Supreme Court Decisions.

In People v. Melongo, Defendant serendipitously recorded three conversations between herself and the Assistant Administrator of the Cook County Court Reporter’s Office and posted the audio to her website. In People v. Clark, Defendant recorded a child support hearing without obtaining the consent of either the judge presiding over the hearing or the opposing attorney. Although the procedural methods in both cases differed, both Defendants challenged the Illinois Eavesdropping Statute on both First Amendment and so-called Substantive Due Process grounds. The Circuit Courts of Cook and Kane County, respectively, agreed the Illinois eavesdropping statute was unconstitutional. Attorneys for the state appealed the decisions all the way to the Illinois Supreme Court.

Without taking our readers on a journey through the academic trappings of both cases, the Illinois Supreme Court agreed the eavesdropping statute violated the First Amendment to the United States and Illinois Constitutions, primarily because the legislation was overly broad. The Court noted the public policy of the statute was to protect conversational privacy. However, the statute as written criminalized conversations never meant to be private. For example, the Court noted the statute criminalized and prohibited recording a loud argument on the street, a political debate in a park and any other conversation loud enough to be overheard by others whether in a private or public setting.

What does this mean for risk managers, investigators and claims adjusters looking to quickly take recorded statements without worrying about uncooperative claimants or witnesses? We point out the IL statute, although currently held to be unconstitutional, is still on the books but the situation is a little murky.

This does not mean, however, that recording of all communications is now universally permitted in Illinois:

  • Recordings may still be subject to the one-party consent rule of the Federal wiretap act.
  • Communications electronically reaching into other states may be subject to the wiretapping laws of the second state and not just Illinois.
  • Secret recordings may still support an Illinois common-law claim for “intrusion into seclusion” or the privacy of another.
  • Another Illinois statute, not necessarily affected by the decision in the Melongo case, makes it illegal to "videotape, photograph, or film" people without their consent in "a restroom, tanning bed, or tanning salon, locker room, changing room or hotel bedroom.”

At present, if you attempt to record a conversation without all parties’ consent you may be violating the precise terms of the law and you might still be subject to criminal prosecution. In practice, we feel it’s highly unlikely prosecutors will try to enforce the law as currently written in light of the IL Supreme Court’s rulings. Our advice to claims adjusters and risk managers taken statements in post-accident investigations—continue to ask for everyone’s consent. This is the best path to avoid litigation.

We also suspect these two decisions by our IL Supreme Court have sent the folks in Springfield scrambling to either amend the statute to make Illinois a “one party consent” state or try to create boundaries or rules where two-party consent may still be appropriate.. Stay tuned to this space for further updates.

This article was researched and written by Joe D’Amato, JD. Joe can be reached for questions and comments at jdamato@keefe-law.com or (312) 756-3708.

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Synopsis: Orthopedic Program at Rush University Medical Center Named Highest Ranked Program in Illinois and #6 in the Nation!!! Analysis by Matthew Ignoffo, J.D.

Editor’s Comment: U.S. News & World Report just released its 2014 rankings for the best hospitals in the nation and we are pleased to report our long-time client at Rush is right at the top. The Report reviewed 1,646 hospital orthopedic programs nationwide. All of these programs treat significant numbers of complicated inpatient cases. Rush is ranked in seven of 16 categories included in the magazine’s 2014-15 “America’s Best Hospitals” issue, which became available online on July 15, and is one of the two top-ranked hospitals in Illinois overall.

Rush remains among a small group of hospitals that rank highly in multiple specialties. Only 144 of the approximately 5,000 hospitals in the United States — approximately 3 percent — scored high enough this year to rank in even one specialty nationally by U.S. News.

Rush’s orthopedics program was ranked No. 6 nationwide, making it the highest ranked orthopedics program in Illinois. Rush’s other ranked programs were geriatrics (No. 17); neurology and neurosurgery (No. 17); nephrology (No. 31); urology (No. 43); cardiology and heart surgery (No. 46); and cancer (No. 48).

U.S. News also noted that the following Rush specialty services are “high-performing”: diabetes and endocrinology; ear, nose and throat; gastroenterology; gynecology; and pulmonary.

In fact, a hospital is reviewed only if it treated at least 338 such inpatients in 2010, 2011 and 2012. Other criteria used in the ranking were reputation with specialists, survival, patient safety, patient volume, nursing intensity and nurse magnet recognition.

As noted in the rankings article, Rush University Medical Center is a 669-bed general medical and surgical facility with 30,810 admissions in the most recent year reported. It performed 10,780 annual inpatient and 9,537 outpatient surgeries. Its emergency room had 55,519 visits. Rush University Medical Center is a teaching hospital.

RUMC It is also accredited by the Commission on Accreditation of Rehabilitation Facilities (CARF). As many of you know, Rush's orthopedic program is entirely staffed by physicians from Midwest Orthopaedics at Rush, also the team physicians for the Chicago Bulls and Chicago White Sox.

This article was researched and written by Matthew Ignoffo, J.D., M.S.C.CPlease feel free to contact Matt at mignoffo@keefe-law.com.

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Synopsis: Did the Folta v. Ferro Engineering ruling end the IL OD Act for hundreds, even thousands of workers? What is the correct insurance coverage for these new claim—GL or EL?

Editor’s comment: We had one of our long-time readers ask an very important question after reading our article on the ruling in Folta. Illinois OD law states (in pertinent part): 

(f) No compensation shall be payable for or on account of any occupational disease unless disablement, as herein defined, occurs within two years after the last day of the last exposure to the hazards of the disease…

If you read that carefully, please note numerous IL OD claims, not just asbestosis, may be drawn into this new “exception” to the OD Act, if the Appellate Court’s ruling isn’t reversed. The provision above confirms IL OD claims require an employee to show “disablement” within two years of the date of exposure to a pathogen. The IL OD Act says nothing about “knowledge” of the ailing worker about the exposure to the pathogen.

In other IL OD rulings, “disablement” is defined as missing one day of work due to the exposure.

This new ruling appears to open up civil liability for OD claims against employers when the worker doesn’t know the link between the pathogen and the later illness until they become sick and/or suffer from an exposure but didn’t know the cause.Consistent with what we feel is the strained logic of Folta, it would appear their medical problems would have to extend past the OD statute of limitations/repose so they “weren’t covered” but could now sue the employer directly in circuit court.

This new ruling would appear to find the employee could sue their employer if they were exposed to a pathogen at work and didn’t know of the bad effects of exposure for a couple/three years. In our view, that happens a lot, particularly in the health care or nursing home field.

Again, if that theory remains IL law, it could open up hundreds of new civil claims for things like “bad building syndrome” where workers claim to be sick for years. To the extent this theory may be opening up lots of new litigation, what do you feel the appropriate coverage might be to protect Illinois employers from such claims?

We would love your thinking. Either way, we feel you need to let your underwriters know about it.

7-14-2014; IL Appellate Court WC Div "Reaches" to Award Benefits; Brad Smith, JD Analyzes EPLI Ruling; David Harrison RIP and more

SynopsisIllinois Appellate Court, WC Division Reversal of Commission/Circuit Court based on manifest weight of the evidence standard appears to be a “reach” but the unique risk created by the nature of claimant’s job compelled reversal. Analysis by John P. Campbell, Jr., J.D.

 

Editor’s Comment: This ruling may be a harbinger of things to come, if Bruce Rauner who is the leading candidate for IL Governor is elected in November and appoints more conservative hearing officers at the IWCC. We may then see numerous denied claims at the IWCC move to the Appellate Court, WC Division to be scrutinized by the justices there. If that scenario plays out, it make take a very long time to get challenging IL WC claims closed.

 

Generally, it is rare to see a reversal at the Appellate Court level based on the manifest weight of the evidence standard. The last two IL Supreme Court rulings on this issue, Sisbro and Twice Over Clean specifically discouraged such reversals. However, we are seeing the Appellate Court, WC Division doing this more and more—substituting their judgment on the facts for that of the IWCC and lower courts. However, both cases cited above were awards by the IWCC that were reversed in the Appellate Court to deny benefits. Since those rulings several years ago, a number of Appellate Court, WC Division unanimous rulings have reversed denials to insure benefits were awarded. We predict this track record will embolden the claimant’s bar to continue appeals to the Appellate level in hopes for reversal, despite the otherwise difficult standard of review. A concern about a reviewing court interposing their judgment on the facts over that of the Arbitrator is the reviewing court is analyzing a transcript where the Arbitrator had the advantage of hearing and seeing Claimant testify. It is similar to reading a text message rather than hearing/seeing someone talk. We feel that seeing a person testify in person and weighing their body language and mannerisms is a dramatically better vantage point to evaluate their truth-telling. Psychology Today confirms 55% of communication is body language and 30% is tone of voice and 7% is the spoken word.

 

Since this standard of review does not permit a substitution of factual interpretation, the appealing party may often try to argue for reversal based on a question of law, which permits a de novo review of the decision and therefore, a lower bar to hurdle while arguing for reversal. Despite an argument by claimant in this case for de novo review, the Appellate Court actually reversed under the manifest weight of the evidence standard. However, their supporting argument reads more like a reversal based on a de novo review of undisputed facts with a legal analysis of what constitutes an employment-related risk vs. “neutral risk” which would otherwise be common to the general public.

 

In the case of Don Young v. IWCC 2014 Il App (4th) 130392WC, Claimant sought benefits for a shoulder injury involving surgery after he felt a “pop” in his shoulder while reaching into a narrow, 3-foot deep box and retrieving an item of approximately 15 lbs.. At trial, the arbitrator found the act of reaching for an item, without more, did not impart an “increased risk” unique to the job an therefore, benefits were denied. However, it is important to also note the arbitrator specifically found claimant’s testimony was not credible, as his version of events was described as inconsistent throughout the medical and trial record. This is important, as the arbitrator’s conclusion in this regard was also attacked by the Appellate Court.

 

The Appellate Court rejected the Commission finding the mechanism of reaching down into a box was no greater than a risk common to the general public. Rather, the Appellate Court found the risk of injury in this case was distinctly associated with claimant’s employment and therefore, cannot be considered a “neutral risk”. A neutral risk has no employment related characteristics. However, in this case, the Court explained that “although the act of ‘reaching’ is one performed by the general public on a daily basis, the evidence in this case established the risk to which claimant was exposed was necessary to the performance of his job duties at the time of injury. His action in reaching and stretching his arm into a deep, narrow box to retrieve a part for inspection was distinctly associated with his employment.”

 

The Court also found the accident reports, medical records and testimony to be far more consistent and credible than the Commission’s ruling. Where the Commission found there to be embellishment and inconsistency regarding the level of stretching and overreaching performed, the Appellate Court noted the accident report described “over extended reaching limits” which was consistent with the medical records and testimony of claimant. In this regard, the Court here appears to havesubstituted their interpretation of facts for that of the Commission in further support of their reversal. That said, it does not appear the Court had to dive into a further analysis of the credibility issue here. Once the Court found the mechanism of injury to be a unique risk of employment (reaching into a narrow 3 foot box to retrieve an item), they had grounds to reverse this decision based on those undisputed facts, regardless of what relative minor inconsistencies there may have been regarding the injury as described. The vast majority of facts were undisputed regarding the size of the box, the weight of items and the mechanism of injury. Therefore, in our reasoned view, this could have been a de novo reversal based on undisputed facts.

 

This reversal, although surprising based on the difficult standard of review, is notable for rather specific circumstances of injury which imparted a risk unique to the employment. Had claimant in this case been reaching down to the floor to pick up a pencil, bag or other innocuous item, we doubt the Court would have ever dispensed a reversal, as such actions are not distinctly associated with the employment. However, where a worker must reach or stretch in a more unusual fashion ( into the bottom of a 3 foot box, which was only 16 inches wide, to pick up an item of about 15 lbs.,) we can understand how this is a mechanism unique to the job and therefore, created an increased risk of injury.

 

This article was researched and written by John P. Campbell, Jr. J.D. You can reach John any time at jcampbell@keefe-law.com.

 

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Synopsis: Employment Practices Claim Gets “Tanked.” Important Seventh Circuit National Origin and Race Discrimination Ruling with analysis by Bradley J. Smith, J.D.

 

Editor’s comment: A former Indian-American T-Mobile employee alleged pay discrimination, wrongful termination, and retaliation pursuant to 42 U.S.C. § 1981. Tank v. T-Mobile USA, Inc., 2014 WL 3360476 (7th Cir. 2014).

 

The Seventh Circuit affirmed the Northern District of Illinois trial court ruling that granted summary judgment for Defendant T-Mobile. On appeal, the Seventh Circuit held: 1) the timing of the internal investigation was not suspicious; 2) the investigator’s questions were not discriminatory; 3) the investigator was not a decision maker; 4) T-Mobile’s proffered reason for termination was not pretext; and 5) Tank’s memorandum to investigator did not allege discrimination.

 

INVESTIGATIONS THAT ARE PROPERLY PERFORMED SHIELD EMPLOYERS

 

Initially, Plaintiff Tank alleged T-Mobile discriminated against him based on his race and national origin, but the Court held he failed to provide sufficient evidence to demonstrate discrimination to a jury. Particularly, Tank failed in his attempt to provide circumstantial evidence through his allegations of suspicious timing and pretext. Here, T-Mobile sent an HR employee to investigate what caused a tumultuous relationship between Tank and another employee. Two complaints from separate sources were submitted as a result of a subsequent meeting about Tank’s behavior with other employees. Consequently, the Vice-President of T-Mobile decided to terminate Tank because he defied his employer’s directive, authorized questionably expenditures of T-Mobile funds, and engaged in favoritism amongst his staff. Tank presented no evidence the HR employee orchestrated the two (2) independent complaints. Ultimately, the Court reasoned a reasonable jury could not find the timing of the investigation suspicious.

 

Next, Tank alleged T-Mobile’s investigation was conducted in an “extraordinary” manner. Nonetheless, Plaintiff failed to offer any corporate policy or other evidence that forbade Corporate Investigations and the HR Department from conducting joint investigations. Further, Tank failed to point to any policy, procedure or other evidence that demonstrated that it was improper for HR to personally select a Corporate Investigations investigator to handle the investigation.

 

Attempting to survive summary judgment, Tank further alleged discriminatory comments by an HR employee and a Vice President. Undoubtedly, a remark can raise an inference of discrimination if it is: 1) made by the individual terminating Tank; 2) at or near the time of the termination decision; and (3) in reference to the termination or other adverse action. Regardless, Tank alleged comments occurred more than three (3) years prior, which even if taken as true, were too remote in time to constitute evidence of discriminatory animus. Furthermore, the Court reasoned the HR employee was not an individual terminating Tank, and thus, even if the comments he made were taken in a light most favorable to Tank, T-Mobile would not be liable for discrimination. Tank attempted to use the cat’s paw theory in the Seventh Circuit, but waived it by not raising it in the District Court.  

 

Next, Tank alleged T-Mobile retaliated against him for complaining about racist conduct towards other employees. Unquestionably, it is against the law to retaliate against an employee for opposing impermissible discrimination. In an attempt to demonstrate retaliation, Tank cited pretext in T-Mobile’s reasoning for his termination. However, the Court determined T-Mobile’s reasons for termination were factually supported by the record. Particularly, T-Mobile’s reasons for termination were consistent.

 

Lastly, Tank alleged comparators were treated more favorably given similar circumstances. Nonetheless, the Court reasoned Tank failed to point to similarly situated employees who were treated more favorably under similar circumstances. Tank also alleged he told the HR employee about racist behavior in a memorandum, however, the memorandum demonstrated no complaint relating to race or national origin.

 

Tank’s pay discrimination claim also failed, as he was unable to point to valid comparators that were similarly situated under the McDonnell Douglas burden-shifting approach. Accordingly, Tank failed to demonstrate a prima facie case of pay discrimination.

 

PROPERLY TRAINING EMPLOYEES/MANAGERS ON HANDLING EMPLOYMENT PRACTICES COMPLAINTS WILL SAVE YOU UNWANTED HEADACHES

 

Although the employer defeated this claim through an expensive summary judgment motion, properly training your employees on handling various types of complaints will undoubtedly limit your liability. Although Plaintiff failed to demonstrate a valid complaint of racist behavior, employers should properly train their staff on handling similar complaints. It will help if and when the EEOC comes knocking.

 

This article was researched and written by Bradley J. Smith, who is our employment law defense team leader. Fully ready to service your legal defense needs, Mr. Smith also manages the firm’s general liability department. Feel free to contact Bradley about this article atbsmith@keefe-law.com.

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Synopsis: David Harrison, Rest in Peace.

 

Editor’s comment: The IL WC community mourns the passing of David C. “Dave” Harrison of Scheele, Cornelius & Harrison. Dave Harrison , age 65, was a resident of Willowbrook, IL, formerly of Matteson, IL. He died unexpectedly on Friday, July 4, 2014 at Adventist Hinsdale Hospital, Hinsdale, IL. He was born March 13, 1949 in Albany, NY. He was licensed to practice law on November 5, 1981. David C. Harrison concentrated his entire legal practice representing injured workers. He  personally handled over 4,000 cases.

 

The defense team at Keefe, Campbell, Biery & Associates knew Dave Harrison to be a quiet and hard-working advocate for his clients. He is the last surviving founding member of the firm. He will be missed.