Prentiss Sullivan v. Centers for New Horizons, Inc. - State of Illinois

The method of proving such allegations is well established.First, Complainant must establish a prima facie showing ofdiscrimination. If he does so, Respondent must articulate alegitimate, non-discriminatory reason for its actions. ForComplainant to prevail, he must then prove that Respondent’sarticulated reason is pretextual. Zaderaka v. Human RightsCommission, 131 Ill. 2d 172, 545 N.E.2d 684 (1989). See alsoTexas Dep’t of Community Affairs v. Burdine, 450 U.S. 251 (1981).The complaint raises two theories, sex discrimination andretaliation.The retaliation theory will be considered first.To establish a prima facie case of retaliation, Complainantwould have to prove three elements. He must prove 1) that heengaged in a protected activity, 2) that Respondent took anadverse action against him, and 3) that there was a causal nexusbetween the protected activity and Respondent’s adverse action.Carter Coal Co. v. Human Rights Commission, 261 Ill. App. 3d 1,633 N.E.2d 202 (5th Dist. 1994). There is no doubt about thefirst and second elements. The parties agree that Complainantfiled a charge of discrimination and that Respondent dischargedhim.There is a dispute, though, about the third element.Respondent maintains that Complainant cannot establish alink between the filing of his charge and his discharge.However, the record does not support Respondent’s position.For purposes of a prima facie case, a connection can beestablished by showing that there was a relatively short time8