Employment Law

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7^th Circuit Court of Appeals

Case Name: Henry Beverly v. Abbott Laboratories

Case No.: 23-2577

Officials: Ripple, Hamilton, and Brennan, Circuit Judges.

Focus: Employment Law

Henry Beverly, a financial analyst employed at Abbott Laboratories, took a personal leave of absence during which he began working for Cook County without notifying Abbott. Although Beverly’s leave was extended twice, his request for a third extension came after Abbott had already filled his position, leading to his termination. Beverly subsequently filed a lawsuit against Abbott, alleging racial discrimination and defamation, among other claims.

The Northern District of Illinois granted summary judgment in favor of Abbott on certain claims related to Beverly’s termination, while allowing others to proceed to trial. Following trial, the jury sided with Abbott on the remaining claims. Beverly appealed the verdict, contesting various pretrial, trial, and post-trial decisions.

The Seventh Circuit determined that the changes in Beverly’s job responsibilities did not constitute constructive discharge, and it found no evidence that Abbott’s rationale for terminating his employment was pretextual. Furthermore, the Seventh Circuit affirmed the district court’s decision to dismiss Beverly’s defamation claim during the trial, deeming the statement in question to be non-actionable opinion. The appellate court also supported the district court’s trial management decisions, including rulings on impeachment strategies and the exclusion of specific evidence, finding no abuse of discretion.

The Seventh Circuit concluded that Beverly’s arguments did not justify a retrial and affirmed the district court’s judgment in its entirety.

Affirmed.

Decided 07/10/24

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