Parrent v. Solvay Fluorides LLC

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THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
TYLER P. PARRENT,
Plaintiff,
vs.
SOLVAY FLUORIDES, LLC,
Defendants.
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Case No. 3:24-cv-01370-GCS
MEMORANDUM & ORDER
SISON, Magistrate Judge:
Now before the Court is Defendant Solvay Fluorides, LLC’s Motion to Dismiss
Count V of Plaintiff’s Amended Complaint and supporting memorandum. (Doc. 35, 35-
1). Count V of Plaintiff’s Amended Complaint alleges that the Defendant “interfered with
and/or harassed the Plaintiff’s exercise” of his religious observances and preferences in
violation of the Illinois Human Rights Act (“IHRA”), 775 I LL . C OMP. S TAT . § 5/1-101, et
seq. (Doc. 31, p. 11-12). Defendant argues that the Amended Complaint fails to allege facts
that support a religious discrimination claim under the IHRA. (Doc. 35-1, p. 1). Plaintiff
filed a Response to Defendant’s Motion to Dismiss on May 5, 2025; Defendant filed a
Reply 	on 	May 	9, 	2025. 	(Doc. 	37, 	38). 	For 	the 	reasons 	given 	below, 	the 	Court
DENIES Defendant’s Motion to Dismiss Count V of Plaintiff’s Amended Complaint.
FACTUAL AND PROCEDURAL BACKGROUND
On April 14, 2025, Plaintiff filed an Amended Complaint against Defendant
alleging, inter alia, that Defendant discriminated against him based on religion in
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violation of the IHRA. (Doc. 31).
Plaintiff alleges he was employed as a technical services specialist by Defendant,
where he provided maintenance services from October 24, 2022, until his termination on
October 12, 2023. (Doc. 31, p. 1). At some point prior to his termination, Plaintiff reported
to unspecified government officials that Defendant’s trucks were unsafe and not fit for
the road. Id. at p. 1-2. He also told his management that the trucks were unsafe, that a
recently deceased trucker’s death should have been reported, and that he would not
participate in Defendant’s illegal activities. Id. at p. 2. Following Plaintiff’s conversations
with the government and Defendant’s management, he experienced “conduct designed
to result in [his] termination.” Id. at p. 2. This included inquiries and harassment from
other employees about his religious beliefs and preferences. Id. Plaintiff observes the
Jewish tradition of kashrut, which prohibits the mixing of meat and dairy products, and
he raises his children in the Jewish faith. Id. at p. 11. Plaintiff told Defendant about these
religious preferences and observances. Plaintiff claims that Defendant discriminated
against him by i) serving only lasagna, which Plaintiff cannot eat, at a Christmas
celebration 	or 	celebrations, 	ii) 	interrogating/harassing 	Plaintiff 	about 	raising 	his
daughter in the Jewish faith, and iii) indicating that Plaintiff’s religious preferences were
not the same as those of other employees. Id. at p. 11-12.
LEGAL STANDARDS
A motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) challenges the
sufficiency of a complaint for failure to state a claim upon which relief may be granted.
See FED. R. C IV. P ROC. 12(b)(6). When considering a Rule 12(b)(6) motion to dismiss, the
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Court must accept all allegations in the complaint as true. See Bell Atlantic Corp. v.
Twombly, 550 U.S. 544, 555 (2007). The federal system of notice pleading requires only that
a plaintiff provide a “short and plain statement of the claim showing that the pleader is
entitled to relief.” FED. R. C IV. P ROC . 8(a)(2). However, the allegations must be “more than
labels and conclusions.” Pugh v. Tribune Co., 521 F.3d 686, 699 (7th Cir. 2008) (citation
omitted). This requirement is satisfied if the complaint: (1) describes the claim in
sufficient detail to give the defendant fair notice of what the claim is and the grounds
upon which it rests; and (2) plausibly suggests that the plaintiff has a right to relief above
a speculative level. See Twombly, 550 U.S. at 555; see also Ashcroft v. Iqbal, 129 S.Ct. 1937,
1949 (2009).
“A claim has facial plausibility when the plaintiff pleads actual content that allows
the court to draw the reasonable inference that defendant is liable for the misconduct
alleged.” Iqbal, 129 S. Ct. at 1949 (citing Twombly, 550 U.S. at 556). However, if “it appears
beyond a doubt that plaintiff can prove no set of facts in support of his claim which would
entitle [him] to relief[,]” the Court must dismiss the claim. Mattice v. Memorial Hosp. of
South Bend, Inc., 249 F.3d 682, 684 (7th Cir. 2001) (citation omitted).
D ISCUSSION
As a preliminary matter, Illinois courts evaluating discrimination claims under the
IHRA apply the same standards as those in Title VII of the Civil Rights Act of 1964 and
the Americans with Disabilities Act (“ADA”). See, e.g., Volling v. Kurtz Paramedic Services,
Inc., 840 F.3d 378, 383 (7th Cir. 2016) (stating that “Illinois courts apply the federal Title
VII framework to IHRA claims.”) (citing Rabé v. United Air Lines, Inc., 971 F.Supp.2d 807,
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821 (N.D. Ill. 2013)); Zaderaka v. Illinois Human Rights Com'n., 545 N.E.2d 684, 687 (Ill. 1989)
(adopting analytical framework established in Supreme Court decisions addressing Title
VII claims for employment discrimination claims under the IHRA); Tate v. Dart, 51 F.4th
789, 793 (7th Cir. 2022) (noting that frameworks for IHRA and ADA analysis are
“practically indistinguishable.”). The Court will use these statutory frameworks to
evaluate Count V of the Amended Complaint.
The parties agree that the Amended Complaint must sufficiently plead the
following elements of a religious accommodation claim. (Doc. 35-1, p. 2-3; Doc. 37, p. 1).
These elements are “(1) the observance or practice conflicting with an employment
requirement is religious in nature; (2) the employee called the religious observance or
practice to the employer's attention; and (3) the religious observance or practice was the
basis for the employee's discharge or other discriminatory treatment.” Adeyeye v.
Heartland Sweeteners, LLC, 721 F.3d 444, 449 (7th Cir. 2013) (citation omitted) (internal
quotations omitted). The Amended Complaint fails to sufficiently plead a conflict
between Plaintiff’s religious observances and practices.
The first element of a religious accommodation claim under the IHRA requires
two things: an observance or practice that is religious in nature and that such observance
or practice conflicts with an employment requirement. Id. Plaintiff’s observance of kashrut
and the decision to raise his daughter in the Jewish faith are plainly religious in nature.
However, as Defendant correctly notes, Plaintiff has not alleged that these religious
observances and practices conflict with an employment requirement. (Doc. 35-1, p. 3-4).
In Adeyeye, there was a conflict between the plaintiff’s religious obligation to perform
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burial rites and the defendant employer’s leave policy. Id. at 449. By contrast, the
allegations in the Amended Complaint do not mention or support an inference of any
employment requirement, let alone an employment requirement that conflicts with
Plaintiff’s religious observances and practices. In other words, it fails to state a claim for
failure to accommodate Plaintiff’s religion.
However, that is not the end of the Court’s analysis. Failure to accommodate
Plaintiff’s religion is not the only cause of action pled under Count V in the Amended
Complaint. While the failure to accommodate claim is Plaintiff’s primary allegation, the
complaint also pleads religious harassment in the alternative. Rule 8 of the Federal Rules
of Civil Procedure permits alternative pleading, and while most alternative pleadings use
“either-or” language to signal the alternative legal theories that have been pled, there is
no requirement that a complaint use that precise language. Rather, a complaint must use
language from which it can be reasonably inferred that there is an alternative pleading.
See Holman v. Indiana, 211 F.3d 399, 407 (7th Cir. 2000). Plaintiff has done so here. Count
V of the amended complaint alleges that Defendant “interrogated and/or harassed
Plaintiff on his choice and reasons for Plaintiff’s desire to raise his daughter in the Jewish
faith.”) (Doc. 31, p. 11-12) (emphasis added). This language is sufficient for the Court to
infer that Plaintiff intended to plead a religious harassment claim in the alternative.
Plaintiff’s Amended Complaint states a claim of religious harassment under the
IHRA. The IHRA prohibits employers from engaging in harassment of an employee. See
775 ILL . C OMP. STAT . § 5/2-102(A). The IHRA defines harassment as:
any unwelcome treatment on the basis of an individual’s actual or
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perceived . . . religion . . . that has the purpose or effect of substantially
interfering 	with 	the 	individual's 	work 	performance 	or 	creating 	an
intimidating, hostile, or offensive working environment. For purposes of
this definition, the phrase “working environment” is not limited to a
physical location an employee is assigned to perform his or her duties.
775 ILL . C OMP. STAT . § 5/2-101(E-1). Plaintiff has asserted that Defendant, through its
employees, engaged in unwelcome treatment by repeatedly questioning Plaintiff about
his religious decisions and underscoring that his religious beliefs were different than
those of other employees. (Doc. 31, p. 11, 12). Taking the allegations in the Amended
Complaint as true, as the Court must at this stage, Plaintiff has stated a viable harassment
claim under the IHRA. Thus, the Court cannot dismiss Count V.
CONCLUSION
For the foregoing reasons, Defendant’s Motion to Dismiss Count V of the
Amended Complaint is DENIED.
IT IS SO ORDERED.
DATED: March 17, 2026.
_______________________________
GILBERT C. SISON
United States Magistrate Judge
Digitally signed
by Judge Sison
Date: 2026.03.17
14:23:17 -05'00'
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