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11 Illinois opinions name it 2 courts 1998–2011 0 in the last five years
The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Inbal Hayut v. State University Of New Yorkgreen2 sentences2006Hayut v. State University of New York, 352 F.3d 733, 745 (2d Cir. 2003). 2006Hayut v. State University of New York, 352 F.3d 733, 745 (2003). | 2 | 2 |
Sangamon County Sheriff's Department v. Illinois Human Rights Commissiongreen2 sentences2011"The 180-day filing requirement is mandatory in order to vest the Commission with subject matter jurisdiction of the charge. [Citations.] * * * A sexual harassment claim based on a hostile work environment generally is made up of a series of events rather than a single event. * * * Provided that an act contributing to the claim occurs within 180 days of the filing date, a fact finder may consider all of the conduct that makes up the hostile environment claim. [Citation.]" Sangamon County Sheriff's Department, 233 Ill.2d at 141 , 330 Ill.Dec. 187 , 908 N.E.2d 39 . ¶ 19 According to petitioners, 2011"The 180-day filing requirement is mandatory in order to vest the Commission with subject matter jurisdiction of the charge. [Citations.] * * * A sexual harassment claim based on a hostile work environment generally is made up of a series of events rather than a single event. * * * Provided that an act contributing to the claim occurs within 180 days of the filing date, a fact finder may consider all of the conduct that makes up the hostile environment claim. [Citation.]" Sangamon County Sheriff's Department, 233 Ill.2d at 141 , 330 Ill.Dec. 187 , 908 N.E.2d 39 . ¶ 19 According to petitioners, | 1 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Gusciara v. Lustig
green
2 sentences2011Illinois has recognized: "The [ Morgan ] Court qualified [its] holding by specifying that an act that occurs within the prescribed period will not enable an employee to recover for acts occurring outside the period if the later act `had no relation to the [earlier] acts' or if, `for some other reason, such as certain intervening action by the employer,' the more recent act was `no longer part of the same hostile environment claim.' [Citation.]" Gusciara, 346 Ill.App.3d at 1019 , 282 Ill.Dec. 449 , 806 N.E.2d 746 (citing Morgan, 536 U.S. at 118 , 122 S.Ct. 2061 ). ¶ 37 The Gusciara court found 2011Illinois has recognized: "The [ Morgan ] Court qualified [its] holding by specifying that an act that occurs within the prescribed period will not enable an employee to recover for acts occurring outside the period if the later act `had no relation to the [earlier] acts' or if, `for some other reason, such as certain intervening action by the employer,' the more recent act was `no longer part of the same hostile environment claim.' [Citation.]" Gusciara, 346 Ill.App.3d at 1019 , 282 Ill.Dec. 449 , 806 N.E.2d 746 (citing Morgan, 536 U.S. at 118 , 122 S.Ct. 2061 ). ¶ 37 The Gusciara court found | 5 | 2004–2011 |
National Railroad Passenger Corporation v. Morgan
green
2 sentences2011Illinois has recognized: "The [ Morgan ] Court qualified [its] holding by specifying that an act that occurs within the prescribed period will not enable an employee to recover for acts occurring outside the period if the later act `had no relation to the [earlier] acts' or if, `for some other reason, such as certain intervening action by the employer,' the more recent act was `no longer part of the same hostile environment claim.' [Citation.]" Gusciara, 346 Ill.App.3d at 1019 , 282 Ill.Dec. 449 , 806 N.E.2d 746 (citing Morgan, 536 U.S. at 118 , 122 S.Ct. 2061 ). ¶ 37 The Gusciara court found 2011Illinois has recognized: "The [ Morgan ] Court qualified [its] holding by specifying that an act that occurs within the prescribed period will not enable an employee to recover for acts occurring outside the period if the later act `had no relation to the [earlier] acts' or if, `for some other reason, such as certain intervening action by the employer,' the more recent act was `no longer part of the same hostile environment claim.' [Citation.]" Gusciara, 346 Ill.App.3d at 1019 , 282 Ill.Dec. 449 , 806 N.E.2d 746 (citing Morgan, 536 U.S. at 118 , 122 S.Ct. 2061 ). ¶ 37 The Gusciara court found | 5 | 2004–2011 |
Jenkins v. Lustig
green
2 sentences2011Alternatively, petitioners assert that Lockard's complaint was not timely filed because the only two acts that occurred less than 180 days before she filed the charge with the Department occurred after certain intervening action by the employer and, therefore, are not components of the actionable hostile environment that may have existed before the intervention. ¶ 20 In Jenkins, the court held that the Morgan rule applies "unless (1) the acts within the jurisdictional period have no relation to those outside the period or (2) are no longer part of the same hostile environment claim. [Citation. 2011Alternatively, petitioners assert that Lockard's complaint was not timely filed because the only two acts that occurred less than 180 days before she filed the charge with the Department occurred after certain intervening action by the employer and, therefore, are not components of the actionable hostile environment that may have existed before the intervention. ¶ 20 In Jenkins, the court held that the Morgan rule applies "unless (1) the acts within the jurisdictional period have no relation to those outside the period or (2) are no longer part of the same hostile environment claim. [Citation. | 3 | 2009–2011 |
Park Crematory v. Illinois Pollution Control Bd.
green
2 sentences1998However, we express no opinion whether the facts of the present case would give rise to a hostile environment claim. 2 We believe that, unlike civil penalties imposed pursuant to the Illinois Environmental Protection Act (415 ILCS 5/42 (West 1992)), which the legislature intended “to provide a method to aid the enforcement of the Act” (see Park Crematory, Inc. v. Pollution Control Board, 264 Ill. 1998However, we express no opinion whether the facts of the present case would give rise to a hostile environment claim. 2: We believe that unlike civil penalties imposed pursuant to the Illinois Environmental Protection Act (415 ILCS 5/42 (West 1992)), which the legislature intended "to provide a method to aid the enforcement of the Act" (see Park Crematory v. Illinois Pollution Control Board , 264 Ill. | 2 | 1998–1998 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.