Robarts v. Illinois Department of Human Services

Filing 19

MOTION by Defendant Illinois Department of Human Services for judgment on the Pleadings (Steimel, Emma)

THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
RICHARD L. ROBARTS,
Plaintiff,
v.

ILLINOIS DEPARTMENT OF
HUMAN SERVICES,
Defendant.

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Case No.: 3:16-cv-50228

Hon. Judge: Frederick J. Kapala

Magistrate Judge: Iain D. Johnston

DEFENDANT’S MOTION FOR JUDGMENT ON THE PLEADINGS
NOW COMES Defendant, Illinois Department of Human Services (“DHS”), by and
through its attorney, Lisa Madigan, Attorney General of the State of Illinois, and respectfully
moves this Court to dismiss Plaintiff’s Complaint pursuant to Federal Rule of Civil Procedure
12(c). In support of its motion, Defendant states the following:
1.

Richard Robarts (“Plaintiff”) is employed by the DHS as a Senior Rehabilitation

Counselor. (Dkt. 1, ¶ 16). Plaintiff is deaf and uses a sign language interpreter to communicate.
(Dkt. 1, ¶ 2).
2.

Judgment on the pleadings is proper as to Plaintiff’s claims under the Illinois

Human Rights Act (IHRA) because these claims are barred by sovereign immunity.
3.

The particular grounds for this motion are set forth in the accompanying

memorandum of law.
WHEREFORE, for the reasons articulated in Defendant’s Memorandum of Law,
Defendant ILLINOIS DEPARTMENT OF HUMAN SERVICES, respectfully requests this

Honorable court grant Defendant’s Motion for Judgment on the Pleadings and any other relief
the Court deems appropriate.
Respectfully submitted,
LISA MADIGAN
Attorney General of Illinois

By:

s/Emma Steimel
EMMA STEIMEL
Assistant Attorney General
General Law Bureau
100 W. Randolph Street, 13th Floor
Chicago, Illinois 60601
[phone]
[e-mail]