Jimmy Lee Bynum, Jr. v. Bandza et al.

Bynum · United States District Court for the Central District of Illinois, Peoria Division · March 13, 2026 · No. 20-CV-2343

Summary

In this post-trial order concerning claims under the Family and Medical Leave Act, the court determined that the defendant acted in good faith and had reasonable grounds for believing its termination decision was lawful, so liquidated damages were denied. The court also denied front pay because the plaintiff had obtained comparable employment, the jury’s back-pay award was substantially lower than the amount sought, and the requested 21-year period was speculative. The court awarded prejudgment interest on the plaintiff’s lost-wage and back-pay damages and directed the plaintiff to submit a damages schedule within 14 days.

Holdings

  1. The defendant established that it acted in good faith and had reasonable grounds for believing that the termination did not violate the FMLA, so the plaintiff was not entitled to liquidated damages.
  2. The plaintiff failed to prove entitlement to front pay, and the court denied that request.
  3. The plaintiff was entitled to prejudgment interest on the jury's lost-wage and backpay award.

Questions Presented

  1. Whether the defendant rebutted the presumption of FMLA liquidated damages by proving that it acted in good faith and had reasonable grounds to believe its termination decision was lawful.
  2. Whether the plaintiff carried his burden of proving entitlement to front pay where he had comparable employment, the jury awarded substantially less back pay than requested, and the requested 21-year period was speculative.
  3. Whether the plaintiff was entitled to prejudgment interest on the jury's backpay award.

Disposition

other

Cases Cited (16)

  • Byrne v. Avon Prods., Inc., 125 F. App'x 704, 705 (7th Cir. 2004)(followed)
  • Holder v. Illinois Dep't of Corr., 751 F.3d 486, 498 (7th Cir. 2014)(followed)
  • Freelain v. Vill. of Oak Park, 888 F.3d 895, 903 (7th Cir. 2018)(followed)
  • Dierlam v. Wesley Jessen Corp., 222 F. Supp. 2d 1052, 1057 (N.D. Ill. 2002)(followed)
  • Hudak v. St. Joseph Cnty. Bd. of Commissioners, No. 3:18-CV-932 RLM, 2021 WL 5121833, at *2 (N.D. Ind. Nov. 4, 2021)(distinguished)
  • Cloutier v. GoJet Airlines, LLC, 996 F.3d 426, 449 (7th Cir. 2021)(followed)
  • Williams v. Pharmacia, Inc., 137 F.3d 944, 954 (7th Cir. 1998)(followed)
  • Downes v. Volkswagen of Am., Inc., 41 F.3d 1132, 1141 (7th Cir. 1994)(followed)
  • Valdivia v. Twp. High Sch. Dist. 214, 2019 WL 699905, at *7 (N.D. Ill. Feb. 20, 2019), aff'd, 942 F.3d 395 (7th Cir. 2019)(followed)
  • McKnight v. Gen. Motors Corp., 973 F.2d 1366, 1372 (7th Cir. 1992)(followed)

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