Narrative Opinion Summary
The case arises from a complaint filed by an employee alleging sex discrimination in Woodward Governor Company's dress code policy, which allowed male employees to wear slacks and boots but prohibited female employees from wearing the same. An administrative law judge found this policy discriminatory, and the Illinois Human Rights Commission upheld the finding. Woodward sought judicial review, and during related federal litigation, a settlement was reached to amend the dress code. The Commission, however, refused to approve the settlement after its final decision, insisting that settlements were not permissible post-decision. The trial court ruled in favor of Woodward, mandating the settlement's approval and requiring payment of attorney fees. On appeal, the court affirmed the trial court's decision, clarifying that the Illinois Human Rights Act permits settlements at any time with mutual agreement and department approval, even after a Commission's final order. The court emphasized that statutory language supports the possibility of settlements beyond the Commission's initial proceedings, reinforcing the settlement's validity prior to the trial court’s decision.
Legal Issues Addressed
Authority of the Illinois Human Rights Commission post-Final Decisionsubscribe to see similar legal issues
Application: The Commission argued that it was not obligated to approve settlements post-final decision, but the court found such settlements permissible under the Act.
Reasoning: The Commission argued that only a 'charge' or 'complaint' could be settled, and once a final decision was rendered, no further settlements could occur.
Interpretation of Section 7.103 of Illinois Human Rights Actsubscribe to see similar legal issues
Application: The court interpreted this section to allow for settlements at any stage unless limited by specific provisions, such as those applicable until a trial court issues a decision.
Reasoning: Moreover, section 7.103 allows for settlements 'at any time,' which should not be interpreted as limited to before a Commission decision.
Settlement Approval under Illinois Human Rights Actsubscribe to see similar legal issues
Application: The court ruled that settlements could be approved even after a final administrative decision, countering the Commission's stance that settlements were only applicable at the 'charge' or 'complaint' stage.
Reasoning: The Illinois Human Rights Act allows settlements at any time with mutual agreement and Department approval, but the court recognized that settlements might still be possible after Commission proceedings.
Sex Discrimination under Illinois Human Rights Actsubscribe to see similar legal issues
Application: The case involves a finding of unlawful sex discrimination due to a company's dress code that imposed different requirements based on gender.
Reasoning: The ALJ's investigation concluded that Woodward's dress code discriminated against female employees by enforcing a more restrictive dress code based on sex and that the policy did not meet a business necessity defense.