On July 27, 2004, three white police officers from Springfield, IL, filed this lawsuit against the city in the U.S. District Court for the Central District of Illinois under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1983. The plaintiffs, represented by private counsel, claimed that the city engaged in race discrimination in violation of Title VII and their right to equal protection under the Fourteenth Amendment. Specifically, the plaintiffs alleged that the city discriminated against them on the basis of race when it gave preferential treatment to a similarly situated African-American colleague when calculating his years of service to the police department for purposes of determining salary and benefits.
At various times between the late-1980s and -1990s, the plaintiffs and their colleague all voluntarily resigned from the Springfield Police Department to pursue other job opportunities. They all eventually sought to rejoin the department. When the plaintiffs reentered the force, they were treated as entry-level officers in terms of pay, benefits, and seniority. When their African-American colleague returned, however, the police department gave him credit for his years of prior service, thereby restoring his pay and benefits to their pre-resignation level. The police department acted pursuant to a new city council ordinance, passed on March 28, 2000, that specifically granted the African-American officer a retroactive leave of absence to enable him to receive credit for his previous service. The city council's stated justifications for the ordinance included diversity in the police force.
This action originally arose in state court. On April 3, 2003, the plaintiffs filed a complaint against the city in the Illinois Circuit Court for the Seventh Judicial District, claiming a violation of the state's equal protection clause. On November 10, 2003, the court dismissed the action as time barred, and the plaintiffs filed a complaint with the Equal Employment Opportunity Commission ("EEOC") on March 2, 2004. The Illinois Appellate Court for the Fourth District affirmed the trial court's decision on July 22, 2004. Groesch v. City of Springfield, 349 Ill. App. 3d 1046 (2004). A few days later, on July 27, the plaintiffs filed this lawsuit in federal district court.
On February 1, 2005, the Court (Judge Jeanne E. Scott) denied the city's motion to dismiss, holding that the original state court judgment did not preclude the plaintiffs from pursuing their claims in federal court. Relying on the "paycheck accrual" rule, the Court explained that each paycheck constituted a separate act of pay discrimination for which the police officers could bring a separate claim. The parties then engaged in discovery for the next year. On July 6, 2006, the Court (Judge Scott) dismissed with prejudice one plaintiff's claims for monetary damages because he had filed for bankruptcy and the city had purchased his damages claims from the bankruptcy estate.
The Court (Judge Scott) granted in part and denied in part the city's motion for summary judgment on December 29, 2006. Groesch v. City of Springfield, 2006 WL 3842085 (C.D. Ill. Dec. 29, 2006). Specifically, the Court dismissed the plaintiffs' claims for damages arising out of paychecks issued before April 3, 2003, the date the plaintiffs initiated the state court action, on the theory of claim preclusion: the plaintiffs could have brought these claims in that earlier state court suit but failed to do so. For similar reasons, the Court also dismissed all other claims that the plaintiffs brought before November 10, 2003, when the state trial court issued its judgment. The Court did, however, allow the plaintiffs to pursue their pay discrimination claims based on paychecks issued after November 10, 2003.
At the request of the parties, the Court (Judge Scott) issued a stay in the proceedings on February 2, 2007, pending the Supreme Court's decision in Ledbetter v. Goodyear Tire and Rubber Co., 550 U.S. 618 (2007). The Ledbetter Court ultimately rejected the paycheck accrual rule and held that the plaintiffs' claims of sex discrimination in pay were time barred. Based on this decision, on July 11, 2007, the district court (Judge Scott) reviewed its December 29 order and dismissed as untimely filed the police officers' remaining Title VII claims. 2007 WL 2684085 (C.D. Ill. July 11, 2007). The Court also dismissed the Section 1983 claims, holding that these claims were barred because they could have been brought in the earlier state court action.
The plaintiffs appealed the district court's decision on August 10, 2007. While the appeal was pending in the U.S. Court of Appeals for the Seventh Circuit, Congress enacted the Lilly Ledbetter Fair Pay Act of 2009, overturning the Supreme Court's decision in Ledbetter v. Goodyear Tire. The Ledbetter Act, which amended Title VII of the Civil Rights Act of 1964, provides that the statute of limitations for filing a pay discrimination claim with the EEOC resets with each discriminatory paycheck.
On March 28, 2011, the Seventh Circuit (Judge William J. Bauer, Judge David F. Hamilton, and Judge Diane P. Wood) ruled on the plaintiffs' appeal. Groesch v. City of Springfield, 635 F.3d 1020 (7th Cir. 2011). In light of the Ledbetter Act, the court reversed the district court in almost every respect, holding that the Act's construction of the paycheck accrual rule meant that the plaintiffs' Title VII and Section 1983 claims were not in fact time barred. The claims filed after the state court judgment, on November 10, 2003, could therefore proceed on remand. But the circuit court affirmed the district court in holding that claim preclusion barred recovery for any claims arising before the state court judgment.
Shortly after the Seventh Circuit's remand, the parties began settlement negotiations. Presumably those negotiations were successful, because on October 16, 2012, the district court (Judge Sue E. Myerscough) acceded to the parties' request and issued an order dismissing the case with prejudice.Brian Tengel - 02/02/2015