Blount v. Stroud, 232 Ill. 2d 302

Summary

The Supreme Court of Illinois held that the circuit court had subject matter jurisdiction over the plaintiff’s common-law retaliatory-discharge claim and her retaliation claim under 42 U.S.C. § 1981. The court concluded that the Illinois Human Rights Act’s exclusive-jurisdiction provision did not bar the common-law claim because it was independently based on the public policy against perjury. It reversed the appellate court’s judgment and remanded for further review.

Holdings

1. The circuit court had subject matter jurisdiction over Blount's common-law retaliatory-discharge claim because the claim rested on an independent public policy against perjury and was not inextricably linked to a civil-rights violation under the Illinois Human Rights Act.
2. The Illinois Human Rights Act did not deprive the circuit court of jurisdiction over Blount's claim under 42 U.S.C. § 1981. Illinois circuit courts may adjudicate federal civil-rights claims, and the Act's administrative procedures do not apply to claims arising under federal law.
3. Subject matter jurisdiction is not dependent on the ultimate success of the claim, the evidence ultimately presented, the correctness of jury instructions, or whether the judgment expressly identifies the statutory theory.

Questions Presented

1. Whether the Illinois circuit court had subject matter jurisdiction over Blount's common-law retaliatory-discharge claim based on her refusal to commit perjury.
2. Whether the Illinois Human Rights Act's jurisdictional limitation required Blount to pursue her federal 42 U.S.C. § 1981 retaliation claim through the Act's administrative procedures rather than in circuit court.
3. Whether the trial evidence, jury instructions, or form of the judgment affected the circuit court's subject matter jurisdiction.

Disposition

reversed_and_remanded