Prentiss Sullivan v. Centers for New Horizons, Inc. - State of Illinois
Prentiss Sullivan v. Centers for New Horizons, Inc. - State of Illinois
Prentiss Sullivan v. Centers for New Horizons, Inc. - State of Illinois
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other words, Complainant does not contest that his program didnot comply with its contract. Since operating within thecontract’s terms is a reasonable expectation <strong>for</strong> Respondent tohave, Complainant’s concession that he did not meet those termsis fatal to his attempts to establish the second element <strong>of</strong> hisprima facie case.The fact that Complainant worked <strong>for</strong> Respondent <strong>for</strong> years isinsufficient to raise a genuine issue <strong>of</strong> fact on that element.After all, there is no allegation that Respondent was aware <strong>of</strong>the shortcomings <strong>of</strong> Complainant’s program until the City <strong>of</strong>Chicago conducted its audit.Similarly, it means nothing that Complainant’s <strong>for</strong>mersupervisor, Gregory Washington, wrote a letter <strong>of</strong> reference <strong>for</strong>him.The letter in question is dated September 22, 1998, be<strong>for</strong>ethe city found that Complainant’s program was not operating.Moreover, the letter itself indicates that that Washington leftRespondent’s employ in May <strong>of</strong> 1995, long be<strong>for</strong>e the auditproblems surfaced. There is no indication whatsoever thatRespondent ever believed that Complainant’s per<strong>for</strong>mance metRespondent’s expectations after the results <strong>of</strong> that audit werereleased.Thus, at the time <strong>of</strong> the discharge (and apparently <strong>for</strong>quite some time be<strong>for</strong>e that), Complainant was not meeting hisemployer’s expectations.Finally, it should be noted that Complainant’s immediatesupervisor in 1999, Ethelyn Taylor, claims that, when she asked11