{ "id": 2607909, "name": "JOSE GONZALEZ, Petitioner, v. THE HUMAN RIGHTS COMMISSION et al., Respondents", "name_abbreviation": "Gonzalez v. Human Rights Commission", "decision_date": "1989-02-02", "docket_number": "No. 88\u20140600", "first_page": "362", "last_page": "371", "citations": [ { "type": "official", "cite": "179 Ill. App. 3d 362" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "472 N.E.2d 596", "category": "reporters:state_regional", "reporter": "N.E.2d", "opinion_index": 0 }, { "cite": "129 Ill. App. 3d 537", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3489841 ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/129/0537-01" ] }, { "cite": "458 N.E.2d 985", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1984, "opinion_index": 0 }, { "cite": "120 Ill. App. 3d 878", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3595086 ], "year": 1984, "opinion_index": 0, "case_paths": [ "/ill-app-3d/120/0878-01" ] }, { "cite": "29 C.F.R. \u00a71601.11", "category": "laws:admin_compilation", "reporter": "C.F.R.", "year": 1968, "opinion_index": 0 }, { "cite": "402 F.2d 357", "category": "reporters:federal", "reporter": "F.2d", "case_ids": [ 2132256 ], "weight": 3, "pin_cites": [ { "page": "360" }, { "page": "360" } ], "opinion_index": 0, "case_paths": [ "/f2d/402/0357-01" ] }, { "cite": "467 N.E.2d 943", "category": "reporters:state_regional", "reporter": "N.E.2d", "opinion_index": 0 }, { "cite": "126 Ill. App. 3d 666", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3597059 ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/126/0666-01" ] }, { "cite": "455 U.S. 385", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 11305742 ], "weight": 9, "pin_cites": [ { "page": "393" }, { "page": "243" }, { "page": "1132" }, { "page": "393" }, { "page": "243" }, { "page": "1132" }, { "page": "398" }, { "page": "246-47" }, { "page": "1135" } ], "opinion_index": 0, "case_paths": [ "/us/455/0385-01" ] }, { "cite": "486 N.E.2d 893", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "pin_cites": [ { "page": "895" } ], "opinion_index": 0 }, { "cite": "109 Ill. 2d 202", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3127069 ], "weight": 2, "pin_cites": [ { "page": "209-10" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/109/0202-01" ] }, { "cite": "373 N.E.2d 1307", "category": "reporters:state_regional", "reporter": "N.E.2d", "opinion_index": 0 }, { "cite": "71 Ill. 2d 61", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5448595 ], "opinion_index": 0, "case_paths": [ "/ill-2d/71/0061-01" ] }, { "cite": "496 N.E.2d 746", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 4, "year": 1978, "pin_cites": [ { "page": "750" }, { "page": "752" } ], "opinion_index": 0 }, { "cite": "146 Ill. App. 3d 340", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3571551 ], "weight": 4, "year": 1978, "pin_cites": [ { "page": "346-49" }, { "page": "346" }, { "page": "349" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/146/0340-01" ] } ], "analysis": { "cardinality": 933, "char_count": 23227, "ocr_confidence": 0.779, "pagerank": { "raw": 2.1434130437934637e-07, "percentile": 0.7675109629943676 }, "sha256": "1cfc50732a2caf7e3375799d382d5e5ec9492790ceec5a6afce52ef6416cb04d", "simhash": "1:7ee7248d8c57b59e", "word_count": 3808 }, "last_updated": "2023-07-14T20:22:52.001106+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [], "parties": [ "JOSE GONZALEZ, Petitioner, v. THE HUMAN RIGHTS COMMISSION et al., Respondents." ], "opinions": [ { "text": "JUSTICE LINN\ndelivered the opinion of the court:\n\u25a0 Petitioner, Jose Gonzalez, was discharged from St. Anne\u2019s Hospital. He filed a charge with the Illinois Department of Human Rights, alleging that the hospital had discharged him in retaliation for his previously filing discrimination charges against St. Anne\u2019s. The Human Rights Commission (Commission) dismissed his complaint as being untimely filed and therefore did not reach the merits.\nGonzalez appeals, contending that his complaint was improperly dismissed because the 180-day period for filing charges in accordance with the Illinois Human Rights Act (Act) (Ill. Rev. Stat. 1983, ch. 68, par. 1 \u2014 101 et seq.) is not a jurisdictional limitation, but rather a statute of limitations that can be equitably tolled and should have been tolled under the circumstances of this case. He had given his typed and signed statement of the charge to the agency within the 180-day period, but it had not been retyped on the Department\u2019s charge form and verified until after that period. Gonzalez additionally argues that the oath and affirmation requirement of the Act is not jurisdictional in the sense that it must be satisfied at the time charges are required to be filed.\nWe reverse and remand.\nBackground\nGonzalez, a former mental health technician with St. Anne\u2019s Hospital, was discharged on July 28, 1983. He filed charges with both the Equal Employment Opportunity Commission (EEOC) and the Illinois Department of Human Rights (Department), claiming that the discharge was discriminatory. The EEOC found no reasonable cause for the charge and therefore issued its letter dismissing the charge and notifying Gonzalez of his right to sue in the Federal district court. The Illinois Human Rights Department, however, eventually determined that Gonzalez\u2019 charge was based on substantial evidence and filed a complaint with the Human Rights Commission, naming St. Anne\u2019s Hospital as respondent.\nThe hospital filed a motion to dismiss on jurisdictional grounds. The administrative law judge (ALJ) held an evidentiary hearing on the motion because of her belief that there were factual issues relating to the timeliness of the filing of the charge.\nAt the hearing Gonzalez testified that he contacted his attorney on January 10 or 11, 1984, concerning a possible action under the Illinois Human Rights Act (Ill. Rev. Stat. 1983, ch. 68, par. 1 \u2014 101 et seq.). The attorney typed up the charge using the Illinois Department of Human Right\u2019s client information sheet (CIS), a form that provides spaces for the pertinent information and for signature, but no space for notarization or oath.\nOn January 20, 1984, at 12:11 p.m., Gonzalez took his signed charge (the CIS form) to the Department for filing. This was 176 days after his discharge. When he went to the Department\u2019s office to file the charge, he was told to wait for the Department to retype it, after which he was to sign it and have it notarized. At this time, the general procedure of the Department was for the CIS form to be submitted to the receptionist for stamping, after which it was given to an intake investigator, who would interview the complaining party. Gonzalez waited two or three hours to be called. However, at 4:30 or 5 p.m. a Department representative told Gonzalez that no typist or notary was available and that he should go home. Someone would then mail him the retyped charge for his signature and for notarization. The receptionist assured Gonzalez that there would be no problem with this procedure.\nGonzalez further testified at the hearing that he called the Department three or four days later to inquire about the charge. He was told that it was on the way. On January 31, 1984, seven days after the expiration of the 180-day period, the Department mailed the charge to him. On that same day, the Department mailed a letter to St. Anne\u2019s, notifying the hospital that Gonzalez had \u201cfiled a charge\u201d against the hospital, which the Department \u201cdocketed *** as an unperfected charge pursuant to its Rules and Regulations,\u201d and that the enclosed charge did not require a response at that time since it was unperfected.\nOn February 13, 1984, Gonzalez returned a signed and notarized copy of the charge, which the Department received on the twenty-third of the month. The Department then investigated the charge and, based upon a finding of substantial evidence of unlawful discrimination, filed its complaint with the Illinois Human Rights Commission against St. Anne\u2019s on February 7,1986.\nSt. Anne\u2019s filed a motion to dismiss the complaint on the grounds that the Department lacked jurisdiction because Gonzalez\u2019 charge was not filed within the 180-day limitation set out in section 7 \u2014 102(A)(1) of the Act. (Ill. Rev. Stat. 1985, ch. 68, par. 7 \u2014 102(A)(1).) In response, the Department, on Gonzalez\u2019 behalf, denied the untimeliness argument, stating that the requirements of the Act had been satisfied by his filing of the CIS form within the 180-day period.\nThe Department told the ALJ that in over 5,000 cases since July 1980, it had docketed unperfected charges. This procedure allowed aggrieved parties to file the CIS form as a charge, without the oath or affirmation, and permitted the treatment of such filings as timely once the Department received back from the claimants retyped charges that were signed and sworn. As far as the Department was concerned, the CIS form contained sufficient information to constitute a charge within the Act. The Act itself does not require any specific form of pleading. See Ill. Rev. Stat. 1987, ch. 68, pars. 1\u2014103(C) (defining charge as \u201can allegation filed with the Department by an aggrieved party\u201d), 7 \u2014 102(A)(2) (\u201cThe charge shall be in such detail as to substantially apprise any party properly concerned as to the time, place, and facts surrounding the alleged civil rights violation\u201d).\nThe ALJ\u2019s recommended order and decision concluded that the charge should be dismissed, finding that the charge was not timely; therefore, the Department and Commission had no jurisdiction over the matter. Further, the ALJ held that the tolling doctrine was inapplicable and could not waive the jurisdictional limit imposed by section 7 \u2014 102(A) of the Act.\nThe Department filed lengthy exceptions to the recommended order and decision, and the hospital filed its response, for the Commission\u2019s review.\nOn January 25, 1988, the Commission entered its order and decision dismissing Gonzalez\u2019 complaint on the ground that the 180-day period was jurisdictional and that the CIS form did not meet the oath and affirmation requirement of the Act. By its decision, the Commission rejected the Department\u2019s contention that its administrative rule conferred jurisdiction under the Act because the rule allowed the submission of a CIS form to be treated as as valid charge, subject to being perfected by oath. Further, the Commission ruled that Gonzalez\u2019 own conduct, not that of the Department, had prevented the timely filing of the charge.\nOpinion\nWe note, initially, that the ALJ and Commission did not accord much weight to the Department\u2019s admitted practices and procedures. Unless these procedures clearly violate the intent of the Human Rights Act, they cannot be considered void. The Department is the body charged with implementing a claimant\u2019s filing under the Act; absent compelling reasons, Gonzalez should not lose the right to a hearing on his claim on the grounds that the Department\u2019s instructions to him were incorrect.\nThe ultimate issue in this case, however, is whether Gonzalez satisfied the statutory requisites for filing his charge. The two related aspects of this issue that the parties raise are: (1) whether the 180-day filing period is jurisdictional (as opposed to being a statute of limitations subject to equitable doctrines, such as tolling) and (2) whether the absence of the claimant\u2019s oath or affirmation at the time the charge is filed is fatal when the charge itself is filed within 180 days but the oath is supplied later. In our view, the case turns on whether the oath, when supplied, cured any technical defect in the charge that Gonzalez had filed within the 180-day period. If so, the filing was timely.\nThe provision that governs the timely filing of the charge states, \u201cWithin 180 days after the date that a civil rights violation allegedly has been committed, a charge in writing under oath or affirmation may be filed with the Department by an aggrieved party or issued by the Department itself under the signature of the Director.\u201d Ill. Rev. Stat. 1987, ch. 68, par. 7 \u2014 102(AX1).\nSt. Anne\u2019s argues that the legislature intended the 180-day period in section 7 \u2014 102(A)(1) to be jurisdictional because section 7 \u2014 102(B), which sets out the 10-day period in which the Department is to give notice of the charge to the respondent, contains an express caveat that the time period in that subsection \u201cshall not be construed to be jurisdictional.\u201d (Ill. Rev. Stat. 1987, ch. 68, par. 7 \u2014 102(B).) The hospital reasons that because the legislature could have put a similar provision in subsection A, but did not, the reasonable construction (by negative implication) is that the 180-day period in that section is jurisdictional.\nWe are not persuaded that section 7 \u2014 102(A)(1) must be construed as jurisdictional in the sense urged by respondent simply because the legislature specifically expressed an intent in subsection B on the effect of an entirely separate time period. The legislature was silent as to the effect of the 180-day period in subsection A, when it could have included express language making that period jurisdictional. Without a divining rod, we cannot discover the legislative intent on this issue.\nTo determine whether a statutory time period is \u201cjurisdictional,\u201d rather than one that can be tolled or waived in some instances, the courts generally attempt to decide whether the right of action created by the particular act is a substantive right unknown at common law and one that also makes the time for filing the charge an inherent element of the right created. If so, it cannot be treated as a statute of limitations. (Pickering v. Human Rights Comm\u2019n (1986), 146 Ill. App. 3d 340, 346-49, 496 N.E.2d 746; cf. Springfield-Sangamon County Regional Plan Comm\u2019n v. Fair Employment Practices Comm\u2019n (1978), 71 Ill. 2d 61, 373 N.E.2d 1307) (noting that under predecessor Fair Employment Practices Act, 180-day filing period, while \u201cmandatory,\u201d was not \u201cjurisdictional\u201d in the sense that it could not be waived). In other words, if meeting the time period is a condition precedent of the plaintiff\u2019s right to seek a remedy, the given time period is jurisdictional. (See Fredman Brothers Furniture Co. v. Department of Revenue (1985), 109 Ill. 2d 202, 209-10, 486 N.E.2d 893, 895.) If the period is treated as a statute of limitations, however, the equitable tolling doctrine or other means of abatement may apply if the circumstances justify it. (E.g., Zipes v. Trans World Airlines, Inc. (1982), 455 U.S. 385, 393, 71 L. Ed. 2d 234, 243, 102 S. Ct. 1127, 1132.) The difference in treatment is that a jurisdictional limitation is considered a part of the liability or cause of action itself, while a statute of limitations operates to preclude the remedy only. Fredman Brothers Furniture Co. v. Department of Revenue (1985), 109 Ill. 2d 202, 486 N.E.2d 893.\nUnder the hospital\u2019s analysis, the statute is jurisdictional and the charge that Gonzalez attempted to file within the 180-day period was insufficient because it did not contain the oath or affirmation of Gonzalez at that time. Under this theory the facts surrounding his filing of the charge and what he was told about filing procedures is irrelevant; it would only be pertinent to the application of an equitable doctrine that would abate the limitations period.\nBoth the ALJ and the Commission relied heavily on the Second District Appellate Court\u2019s decision in Pickering v. Human Rights Comm\u2019n (1986), 146 Ill. App. 3d 340, 496 N.E.2d 746. The plaintiff in that case filed a charge of age and handicap discrimination almost a year after his termination. Rejecting the argument that section 7\u2014 102(A) of the Act should be treated as a statute of limitations, the court concluded that since \u201cthe act itself creates substantive rights unknown at common law and at the same time prescribes the time within which a party must file\u201d the charge, \u201cthe 180-day filing requirement must be deemed to be jurisdictional.\u201d 146 Ill. App. 3d at 346, 496 N.E.2d at 750.\nIn Pickering, the claimant had done nothing to pursue his claim for almost a year after the alleged discrimination, despite conferring with an attorney, and the Department dismissed the charge. The Commission sustained the dismissal, citing lack of jurisdiction over the matter. The trial court, on administrative review, reversed and remanded for a hearing on the plaintiff\u2019s contention that tolling, waiver, or other equitable considerations applied. In reversing the trial court, the appellate court concluded that once it found the 180-day period to be jurisdictional, no equitable doctrines were available to circumvent that limit, with the narrow exception of estoppel. Citing Lee v. Human Rights Comm\u2019n (1984), 126 Ill. App. 3d 666, 467 N.E.2d 943, the Pickering court held that the 180-day period would be extended only if the agency\u2019s misleading conduct caused the claimant to miss the deadline. Pickering, 146 Ill. App. 3d at 349, 496 N.E.2d at 752.\nEven under Pickering, Gonzalez would appear to have a good claim to estoppel as an exception to the limitation period. We do not adopt Pickering\u2019s rationale or holding that the 180-day period is jurisdictional, however. Because of our conclusion that the filing in this case was timely, we need not decide the broader question of whether the filing period in section 7 \u2014 102(A)(1) is jurisdictional or a statute of limitations.\nWe believe that the narrower, dispositive issue in this case centers on the oath and affirmation requirement of section 7 \u2014 102(A): Does the unperfected charge, timely filed, become a nullity if the oath is supplied after the 180-day period, or does the supplying of the oath \u201crelate back\u201d to the original filing? The hospital argues that the absence of Gonzalez\u2019 verified signature on the CIS form he filed with the Department is absolutely fatal to his ability to maintain his claim. Like the jurisdictional argument, this one provides for no leeway, no relaxation of rigid rules.\nAs an alternative argument, the hospital cites Gonzalez\u2019 own conduct as being responsible for the dismissal of his charge. This suggests, perhaps unfairly, that one who files a defective charge toward the end of the limitation period is less diligent than one who starts the filing procedure earlier and therefore has a better chance of curing any defect within the 180-day period.\nGonzalez does not contend that the Department should act upon unsworn charges or that he was excused from furnishing his oath for the charge contained in his CIS form. Rather, he points out that the Department itself treated the unsworn CIS form as an \u201cunperfected\u201d charge, but a charge nonetheless, to be docketed in accordance with its rules. Section 2520.350 of the Department\u2019s rules allows the acceptance of a charge which \u201ccomplies substantially\u201d with the requirements of the Act but \u201cwhich is not notarized\u201d or is lacking other elements. Such statement is treated as an unperfected charge, to be docketed, and the Department is to send the claimant a letter specifying which elements must be supplied to perfect the charge. The very language of this section demonstrates the validity of the unperfected charge; it is not considered void, merely inchoate. The Department, in fact, takes jurisdiction over the charge; it merely declines to proceed unless and until the missing element, such as notarization, is supplied.\nThis practice is consonant with another Department rule, section 2520.360, which allows \u201ca charge or any part thereof\u201d to be \u201camended by the complainant to cure technical defects or omissions, or to clarify or amplify allegations made therein ***, and such amendments shall relate back to the original filing date.\u201d Under this rule, if the absence of the oath at the time the charge was filed is considered a technical omission, Gonzalez\u2019 filing was not untimely. This is how the Department viewed it.\nWe agree with the Department\u2019s interpretation of its own rules. Gonzalez was expressly assured by the Department that he could leave the CIS form for retyping, that it would then be mailed out for his signature and oath, and that there would be \u201cno problem\u201d with this procedure. The Department in fact had followed that procedure and accepted unperfected charges in thousands of cases. Following its own rules, the Department did not act on the charge until it had been perfected. The hospital was not prejudiced in any way, nor was it faced with a stale claim. Notice of the unperfected charge was sent to the hospital upon its receipt. Gonzalez supplied his notarized signature within a reasonable time after receiving the typed charge in the mail.\nWe do not suggest that the oath requirement is a technicality in the sense that it need never be supplied or that it is an insignificant part of the charge. Requiring a claimant to make his allegations under oath may minimize frivolous filings. However, the Department\u2019s own rules permit the filing of charges without notarization and permit liberal amendment to cure technical omissions. Since Gonzalez filed his unperfected CIS form within the 180-day period, it was not in fact untimely because the subsequent filing of the oath or affirmation \u201crelates back\u201d to the initial filing.\nSound support for this interpretation is found in Choate v. Caterpillar Tractor Co. (7th Cir. 1968), 402 F.2d 357. The Seventh Circuit held that the oath requirement for a charge under Title VII was not a jurisdictional prerequisite to maintaining the claim. The court expressly cited the EEOC\u2019s regulation which allows aggrieved parties to amend their complaints \u201c \u2018to cure technical defects or omissions, including failure to swear to the charge.\u2019 \u201d (402 F.2d at 360, quoting 29 C.F.R. \u00a71601.11 (1968).) Amendments made under this regulation relate back to the original filing date. 402 F.2d at 360.\nAs long as the original charge is filed within the 180-day period, as it was here, a liberal amendment policy makes sense. The hospital received prompt notice but did not have to act on the unperfected charge. If Gonzalez had never supplied the oath, nothing more would have happened. Moreover, if Gonzalez had waited an unreasonable amount of time before furnishing the oath he may not have been entitled to proceed on his claim. Under equitable principles, a claimant attempting to benefit from a tolling or other abatement of the 180-day period might well find himself barred by laches if he failed to act expeditiously.\nHere, no facts indicate that Gonzalez intended to abandon his claim. Within a reasonable time after receiving the typed charge from the Department, he furnished his oath. Whether he could or should have gotten his CIS form on file before the 176th day is a factual matter that is immaterial to the legal issues raised. The ALJ accepted Gonzalez\u2019 unrebutted testimony as to the factual circumstances surrounding the filing. The Commission\u2019s comments to the effect that Gonzalez\u2019 conduct was responsible for the tardy filing are not probative on the ultimate issues in this case and may be disregarded.\nBased on our reading of the statute and the pertinent authorities, we hold that the CIS charge, plus the later supplied oath, satisfied section 7 \u2014 102 of the Act in this case. Accordingly, the charge was not untimely filed.\nFor the foregoing reasons, we reverse the Commission\u2019s order and remand this cause for proceedings on the merits.\nReversed and remanded.\nJOHNSON and McMORROW, JJ., concur.\nThe Department\u2019s CIS form allows the aggrieved party to set out the pertinent allegations. There is a space for signature, but not for oath or notarization. The Department then takes the CIS information and retypes it on another form. This form, entitled \u201cCharge of Discrimination,\u201d contains a printed block that states \u201cI swear or affirm that I have read the above charge and that it is true to the best of my knowledge, information and belief.\u201d There is a space for the complainant\u2019s signature underneath, as well as a space for notarization.\nPickering acknowledged that one of the criteria for determining whether the limitation period is jurisdictional is whether the right in question is created by the statute or whether the statute merely provides the procedural framework for redressing the right. The Illinois Human Rights Act states its aim is \u201cto secure and guarantee the rights established by Sections 17, 18, and 19 of Article I of the Illinois Constitution of 1970.\u201d (Ill. Rev. Stat. 1987, ch. 68, par. 1 \u2014 102(C).) Several courts view the Act as the procedural vehicle for enforcing the constitutional right to be free from unlawful discrimination. (E.g., Thakkar v. Wilson Enterprises, Inc. (1988), 120 Ill. App. 3d 878, 458 N.E.2d 985; Dilley v. Americana Healthcare Corp. (1984), 129 Ill. App. 3d 537, 472 N.E.2d 596.) Pickering\u2019s holding that at least some of the rights secured in the Act were of statutory, rather than constitutional, origin apparently influenced the court\u2019s decision that the 180-day period was an inherent part of the cause of action and thus jurisdictional.\nWe believe, however, that the more persuasive authority on the jurisdictional issue is the United States Supreme Court\u2019s interpretation of the Federal counterpart to the Illinois Human Rights Act. In Zipes v. Trans World Airlines, Inc. (1982), 455 U.S. 385, 393, 71 L. Ed. 2d 234, 243, 102 S. Ct. 1127, 1132, the Court interpreted Title VII of the Civil Rights Act of 1964, 42 U.S.C. \u00a72000e et seq. (1970), holding that filing a timely charge of discrimination with the EEOC was not a jurisdictional prerequisite to suit in the Federal court but was in the nature of a statute of limitations subject to waiver, estoppel, and equitable tolling. After enumerating its considered reasons for this construction of the time period, the Court noted that employers\u2019 right to prompt notice of claims would not be undercut by treating the period as a statute of limitations. Zipes, 455 U.S. at 398, 71 L. Ed. 2d at 246-47, 102 S. Ct. at 1135.\nThe Commission stated, \u201cAlthough the Department of Human Rights was taking the position that the Complainant\u2019s CIS form was a timely charge, the Complainant, who was represented by counsel, had no right to rely on that interpretation. The Complainant\u2019s counsel had the duty to read the statute, and comply with its plain meaning.\u201d", "type": "majority", "author": "JUSTICE LINN" } ], "attorneys": [ "Stephen Stern and Brian Smith, both of Legal Assistance Foundation of Chicago, of Chicago, for petitioner.", "Vedder, Price, Kaufman & Kammholz, of Chicago (Richard H. Schnadig and Kim A. Liffert, of counsel), for respondents." ], "corrections": "", "head_matter": "JOSE GONZALEZ, Petitioner, v. THE HUMAN RIGHTS COMMISSION et al., Respondents.\nFirst District (4th Division)\nNo. 88\u20140600\nOpinion filed February 2, 1989.\nStephen Stern and Brian Smith, both of Legal Assistance Foundation of Chicago, of Chicago, for petitioner.\nVedder, Price, Kaufman & Kammholz, of Chicago (Richard H. Schnadig and Kim A. Liffert, of counsel), for respondents." }, "file_name": "0362-01", "first_page_order": 384, "last_page_order": 393 }