whistleblower claim in Illinois

2017See Ulm v. Memorial Medical Center, 2012 IL App (4th) 110421, ¶ 36 (the trial court did not err by granting the defendant summary judgment on the plaintiff’s whistleblower claim when the plaintiff’s refusal to sign a certification accompanying a subpoenaed medical record did not violate any law “even assuming [the] defendant fired [the plaintiff] in retaliation for so refusing”); Sardiga, 409 Ill.

2017See Ulm v. Memorial Medical Center, 2012 IL App (4th) 110421, ¶ 36 (the trial court did not err by granting the defendant summary judgment on the plaintiff’s whistleblower claim when the plaintiff’s refusal to sign a certification accompanying a subpoenaed medical record did not violate any law “even assuming [the] defendant fired [the plaintiff] in retaliation for so refusing”); Sardiga, 409 Ill.

2017See Dubina v. Mesirow Realty Development, Inc., 178 Ill. 2d 496, 503 (1997) (“[t]he order of voluntary dismissal, because it disposed of all matters pending before the circuit court, rendered all orders which were final in nature, but which were not previously appealable, immediately final and appealable”). ¶ 13 ANALYSIS ¶ 14 Plaintiff contends that the trial court erroneously granted defendant’s motion for summary judgment because defendant asked plaintiff to falsify the AIR which directly violated Albea’s rights to benefits under the Workers’ Compensation Act.

2017See Dubina v. Mesirow Realty Development, Inc., 178 Ill. 2d 496, 503 (1997) (“[t]he order of voluntary dismissal, because it disposed of all matters pending before the circuit court, rendered all orders which were final in nature, but which were not previously appealable, immediately final and appealable”). ¶ 13 ANALYSIS ¶ 14 Plaintiff contends that the trial court erroneously granted defendant’s motion for summary judgment because defendant asked plaintiff to falsify the AIR which directly violated Albea’s rights to benefits under the Workers’ Compensation Act.

2017See Ulm v. Memorial Medical Center, 2012 IL App (4th) 110421, ¶ 36 (the trial court did not err by granting the defendant summary judgment on the plaintiff’s whistleblower claim when the plaintiff’s refusal to sign a certification accompanying a subpoenaed medical record did not violate any law “even assuming [the] defendant fired [the plaintiff] in retaliation for so refusing”); Sardiga, 409 Ill.

2017See Ulm v. Memorial Medical Center, 2012 IL App (4th) 110421, ¶ 36 (the trial court did not err by granting the defendant summary judgment on the plaintiff’s whistleblower claim when the plaintiff’s refusal to sign a certification accompanying a subpoenaed medical record did not violate any law “even assuming [the] defendant fired [the plaintiff] in retaliation for so refusing”); Sardiga, 409 Ill.

2013Retaliatory Discharge ¶ 31 Illinois follows the general rule that an at-will employee may be discharged “ ‘for any reason or no reason.’ ” Turner v. Memorial Medical Center, 233 Ill. 2d 494, 500 (2009) (quoting Zimmerman v. Buchheit of Sparta, Inc., 164 Ill. 2d 29, 32 (1994)).

2013Retaliatory Discharge ¶ 31 Illinois follows the general rule that an at-will employee may be discharged “ ‘for any reason or no reason.’ ” Turner v. Memorial Medical Center, 233 Ill. 2d 494, 500 (2009) (quoting Zimmerman v. Buchheit of Sparta, Inc., 164 Ill. 2d 29, 32 (1994)).

2013Retaliatory Discharge ¶ 31 Illinois follows the general rule that an at-will employee may be discharged “ ‘for any reason or no reason.’ ” Turner v. Memorial Medical Center, 233 Ill. 2d 494, 500 (2009) (quoting Zimmerman v. Buchheit of Sparta, Inc., 164 Ill. 2d 29, 32 (1994)).

2013Retaliatory Discharge ¶ 31 Illinois follows the general rule that an at-will employee may be discharged “ ‘for any reason or no reason.’ ” Turner v. Memorial Medical Center, 233 Ill. 2d 494, 500 (2009) (quoting Zimmerman v. Buchheit of Sparta, Inc., 164 Ill. 2d 29, 32 (1994)).

2013See, e.g., Arroyo, 648 A.2d at 1077-78 (holding that statements that a university research associate made about the department chairman’s alleged fabrication of data in a published scientific paper to the investigatory committee of the university were not absolutely privileged for purposes of the chairman’s defamation action against the associate; holding that the proceedings lacked the requisite safeguards to qualify as judicial or quasi-judicial, since, inter alia, the complaint commencing the proceedings was not made under oath, the proceedings were not public, the witnesses were not under

2013See Smith, 231 Ill. 2d at 118 . -19- 2013 IL App (2d) 130006 Our conclusion that defendant is not immune from liability for plaintiff’s discharge obviates the need to determine whether the acts of Fletcher and Carlson actually were discretionary. ¶ 66 CONCLUSION ¶ 67 For the preceding reasons, the dismissal of plaintiff’s whistleblower claim is affirmed, the dismissal of plaintiff’s retaliatory discharge claim is reversed, and the cause is remanded for further proceedings consistent with this opinion. ¶ 68 Affirmed in part and reversed in part; cause remanded. -20-

2013See Smith, 231 Ill. 2d at 118 . -19- 2013 IL App (2d) 130006 Our conclusion that defendant is not immune from liability for plaintiff’s discharge obviates the need to determine whether the acts of Fletcher and Carlson actually were discretionary. ¶ 66 CONCLUSION ¶ 67 For the preceding reasons, the dismissal of plaintiff’s whistleblower claim is affirmed, the dismissal of plaintiff’s retaliatory discharge claim is reversed, and the cause is remanded for further proceedings consistent with this opinion. ¶ 68 Affirmed in part and reversed in part; cause remanded. -20-

2013We affirm the dismissal of the whistleblower claim, reverse the dismissal of the retaliatory discharge claim, and remand the cause for further proceedings. 2013 IL App (2d) 130006 ¶3 FACTS ¶4 In his amended complaint, plaintiff alleged the following facts common to both claims.