Case: Karraker v. Rent-A-Center Inc.

2:02-cv-02026 | U.S. District Court for the Central District of Illinois

Filed Date: Jan. 28, 2002

Closed Date: 2005

Clearinghouse coding complete

Case Summary

On January 28, 2002, current and former employees, on behalf of themselves and others similarly situated, sued their employer, Rent-A-Center, Inc. (RAC), in the U.S. District Court for the Central District of Illinois, under the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq. and state laws. The plaintiffs, represented by private counsel, sought declaratory, injunctive, and monetary relief as well as class certification. On March 22, 2002, the plaintiffs amended their complaint, and…

On January 28, 2002, current and former employees, on behalf of themselves and others similarly situated, sued their employer, Rent-A-Center, Inc. (RAC), in the U.S. District Court for the Central District of Illinois, under the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq. and state laws. The plaintiffs, represented by private counsel, sought declaratory, injunctive, and monetary relief as well as class certification.

On March 22, 2002, the plaintiffs amended their complaint, and added Associated Personnel Technicians (APT) as a co-defendant. In their amended complaint, they challenged RAC's policy that required all employees and external applicants seeking management positions to take a series of tests, collectively referred to as the management test. They alleged that APT scored and interpreted the management test for RAC, and the results were compiled into psychological profiles, sent to the employees' immediate supervisors and placed in their personal files.

Part of the test involved questions from the Minnesota Multiphasic Personality Inventory (MMPI), a test RAC said it used to measure personality traits, but it was in fact also a psychological test that helped psychologists to diagnose and treat individuals with psychiatric disorders. RAC declined to promote any employee with more than 12 deviations reflected in the test score. The plaintiffs in this case had more than 12 deviations on the test, and were not promoted as a result.

While the discovery was still ongoing, on January 8, 2003, the District Court (Judge Michael P. McCuskey) dismissed the plaintiffs' FCRA claim and limited the scope of one of their three state claims. Karraker v. Rent-A-Ctr., Inc., 239 F. Supp. 2d 828 (C.D. Ill. 2003). In addition, the Court allowed the plaintiffs to add a claim under the Americans with Disabilities Act (ADA), 42 U.S.C. § 12111 et seq., to their second amended complaint. The Court also resolved the jurisdiction disputes about APT, and terminated the defendant CEO for lack of jurisdiction, leaving RAC and APT as the remaining defendants. The plaintiffs filed their second amended complaint on the same day.

In the second amended complaint, the ADA claims were brought by only one of the plaintiffs (the ADA plaintiff), as he was the only one who filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC). He alleged that he was discharged by RAC in retaliation for protesting the test, and that RAC's use of the MMPI as part of its testing program violated the ADA. Subsequently, the plaintiffs filed a motion for class certification, and RAC filed a motion for partial summary judgment.

On February 17, 2004, the Court granted in part and denied in part RAC's motion and entered in favor of RAC on the ADA claims of denial of promotions (based on the claim's untimeliness) and retaliation. The Court also granted in part and denied in part the plaintiffs' class certification motion. A class was certified as all past and present employees of RAC in Illinois who took the Test.

The plaintiffs and the defendants filed cross motions for summary judgment. On May 7, 2004, the Court granted summary judgment in the defendants' favor on the plaintiffs' state law claims and the administration of the test claim, while the termination claim was still pending. Karraker v. Rent-A-Ctr., Inc., 316 F. Supp. 2d 675 (C.D. Ill. 2004). The Court entered judgment in APT's favor and terminated APT from the action, leaving RAC as the only defendant. With regard to the administration of the Test claim, the Court found that RAC's use of MMPI as part of the Test was not medical examination for purposes of the ADA and thus not in violation of the ADA.

The plaintiffs appealed the summary judgment rulings to the 7th Circuit and stipulated the dismissal of the termination claim to allow the appeal to go forward. The 7th Circuit issued its decision on June 14, 2005, affirming the dismissal of the ADA claim of denial of promotions and state law claims, while reversing in part and remanding the case back to the District Court. Karraker v. Rent-A-Ctr., Inc., 411 F.3d 831 (7th Cir. 2005). The Court of Appeals, in an opinion by Judge Terence T. Evans, found that the MMPI was a medical examination under the ADA, so the summary judgment ruling could be entered in the plaintiffs' favor regarding this claim.

On remand, the District Court entered summary judgment in the plaintiffs' favor regarding the administration claim in a text order. On August 12, 2005, the Court ordered RAC to search for and removed all scores and narratives of the Test from its facilities, and not to consider those results in making any employment decision for its Illinois employees. Karraker v. Rent-A-Ctr., Inc., 2005 WL 2001511 (C.D. Ill. Aug. 12, 2005). The Court also re-opened the ADA plaintiff's termination claim by agreement of both parties.

RAC then filed a summary judgment motion, arguing that the termination claim should be dismissed under the doctrine of judicial estoppel. The Court agreed and entered summary judgment in RAC's favor regarding the termination claim on November 7, 2005. Karraker v. Rent-A-Ctr., Inc., 2005 WL 2979652 (C.D. Ill. Nov. 7, 2005). The plaintiffs petitioned for attorneys' fees and moved for compensation for class representative, the ADA plaintiff. On May 19, 2006, the Court denied the petition, holding that the plaintiffs were not the prevailing party, and granted the motion, awarding $5,000 in compensation to the ADA plaintiff. Karraker v. Rent-A-Ctr., Inc., 431 F. Supp. 2d 883 (C.D. Ill. 2006). The plaintiffs appealed the decision to the 7th Circuit.

On July 19, 2007, the 7th Circuit Court, in an opinion by Judge Evans, held that the plaintiffs were prevailing parties and thus were entitled to attorneys' fees. Karraker v. Rent-A-Ctr., Inc., 492 F.3d 896 (7th Cir. 2007). The Court vacated the denial order and remanded for a determination of a reasonable award of attorneys' fees. Judge Joel M. Flaum dissented.

On remand, the District Court awarded $155,328.85 in attorneys' fees and litigation costs to the plaintiffs and issued a final judgment. Karraker v. Rent-A-Ctr., Inc., 2008 WL 1990346 (C.D. Ill. May 2, 2008). RAC appealed to the 7th Circuit, but later voluntarily dismissed the appeal. This ended the case.

Summary Authors

Emma Bao (8/7/2013)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4624566/parties/karraker-v-rent-a-center-inc/


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Documents in the Clearinghouse

Document

2:02-cv-02026

Docket [PACER]

Karraker v. Rent-A-Center Incorporated

July 27, 2009

July 27, 2009

Docket
70

2:02-cv-02026

Order

Karraker v. Rent-A-Center

Jan. 8, 2003

Jan. 8, 2003

Order/Opinion

239 F.Supp.2d 239

183

2:02-cv-02026

Opinion

Karraker v. Rent-A-Center Incorporated

May 7, 2004

May 7, 2004

Order/Opinion

316 F.Supp.2d 316

04-02881

Opinion

Karraker v. Rent-A-Center

U.S. Court of Appeals for the Seventh Circuit

June 14, 2005

June 14, 2005

Order/Opinion

411 F.3d 411

216

2:02-cv-02026

Opinion

Karraker v. Rent-A-Center Incorporated

Aug. 12, 2005

Aug. 12, 2005

Order/Opinion

2005 WL 2005

240

2:02-cv-02026

Opinion

Karraker v. Rent-A-Center Incorporated

Nov. 7, 2005

Nov. 7, 2005

Order/Opinion

2005 WL 2005

269

2:02-cv-02026

Opinion

Karraker v. Rent-A-Center

May 19, 2006

May 19, 2006

Order/Opinion

431 F.Supp.2d 431

06-02617

Opinion

Karraker v. Rent-A-Center

U.S. Court of Appeals for the Seventh Circuit

July 9, 2007

July 9, 2007

Order/Opinion

492 F.3d 492

299

2:02-cv-02026

Opinion

Karraker v. Rent-A-Center

May 2, 2008

May 2, 2008

Order/Opinion

2008 WL 2008

Docket

See docket on RECAP: https://www.courtlistener.com/docket/4624566/karraker-v-rent-a-center-inc/

Last updated March 26, 2024, 3:01 a.m.

ECF Number Description Date Link Date / Link
1

Complaint

Jan. 28, 2002

Jan. 28, 2002

PACER
2

Filing Fee Received

Jan. 28, 2002

Jan. 28, 2002

PACER
3

Service - Miscellaneous

March 11, 2002

March 11, 2002

PACER
4

Amended Complaint

March 22, 2002

March 22, 2002

PACER
5

Notice of Appearance of Attorney

March 25, 2002

March 25, 2002

PACER
6

Motion to Dismiss

April 10, 2002

April 10, 2002

PACER
7

Memorandum in Support of Motion

April 10, 2002

April 10, 2002

PACER
8

Summons Issued

April 15, 2002

April 15, 2002

PACER
9

Certificate of Interest

April 17, 2002

April 17, 2002

PACER

Order

April 24, 2002

April 24, 2002

PACER
10

Motion for Extension of Time to File

April 24, 2002

April 24, 2002

PACER
11

Service - Miscellaneous

April 26, 2002

April 26, 2002

PACER
12

Motion for Extension of Time to File

April 30, 2002

April 30, 2002

PACER
13

Service - Miscellaneous

May 1, 2002

May 1, 2002

PACER
14

Motion for Miscellaneous Relief

May 2, 2002

May 2, 2002

PACER
15

Memorandum in Support of Motion

May 2, 2002

May 2, 2002

PACER
16

Answer - Miscellaneous

May 8, 2002

May 8, 2002

PACER
17

Response to Motion

May 17, 2002

May 17, 2002

PACER

Order

May 22, 2002

May 22, 2002

PACER

Minutes - Miscellaneous

May 22, 2002

May 22, 2002

PACER
18

Motion for Extension of Time to File

May 28, 2002

May 28, 2002

PACER
19

Certificate of Interest

May 28, 2002

May 28, 2002

PACER
20

Notice of Appearance of Attorney

May 28, 2002

May 28, 2002

PACER
21

Order

May 28, 2002

May 28, 2002

PACER

Order

May 29, 2002

May 29, 2002

PACER
22

Response to Motion

June 7, 2002

June 7, 2002

PACER
23

Motion for Leave to File

June 7, 2002

June 7, 2002

PACER
24

Motion to Dismiss

June 14, 2002

June 14, 2002

PACER
25

Memorandum in Support of Motion

June 14, 2002

June 14, 2002

PACER
26

Memorandum in Opposition to Motion/Petition

June 21, 2002

June 21, 2002

PACER
27

Motion for Extension of Time to File

June 26, 2002

June 26, 2002

PACER
28

Notice of Appearance of Attorney

June 27, 2002

June 27, 2002

PACER
29

Response to Motion

June 27, 2002

June 27, 2002

PACER
30

Memorandum in Opposition to Motion/Petition

June 27, 2002

June 27, 2002

PACER
31

Response to Motion

June 27, 2002

June 27, 2002

PACER
32

Motion to Dismiss

June 27, 2002

June 27, 2002

PACER
33

Memorandum in Support of Motion

June 27, 2002

June 27, 2002

PACER
34

Discovery - Miscellaneous

July 1, 2002

July 1, 2002

PACER
35

Discovery - Miscellaneous

July 1, 2002

July 1, 2002

PACER
36

Motion to Bifurcate

July 1, 2002

July 1, 2002

PACER
37

Memorandum in Support of Motion

July 1, 2002

July 1, 2002

PACER
38

Miscellaneous Document

July 2, 2002

July 2, 2002

PACER

Order

July 3, 2002

July 3, 2002

PACER

Minutes - Miscellaneous

July 8, 2002

July 8, 2002

PACER
39

Motion for Order

July 8, 2002

July 8, 2002

PACER
40

Motion for Leave to File

July 8, 2002

July 8, 2002

PACER
41

Response to Motion

July 9, 2002

July 9, 2002

PACER
42

Motion for Extension of Time to File

July 9, 2002

July 9, 2002

PACER
43

Notice (Other)

July 12, 2002

July 12, 2002

PACER

Minutes - Miscellaneous

July 15, 2002

July 15, 2002

PACER
44

Response to Motion

July 15, 2002

July 15, 2002

PACER
45

Response to Motion

July 15, 2002

July 15, 2002

PACER
46

Reply

July 19, 2002

July 19, 2002

PACER
47

Order

July 26, 2002

July 26, 2002

PACER
48

Motion for Leave to File

July 29, 2002

July 29, 2002

PACER

Order

July 31, 2002

July 31, 2002

PACER
49

Motion to Cite Authority

July 31, 2002

July 31, 2002

PACER

Order

Aug. 1, 2002

Aug. 1, 2002

PACER
50

Response to Motion

Aug. 2, 2002

Aug. 2, 2002

PACER
51

Notice (Other)

Aug. 9, 2002

Aug. 9, 2002

PACER
52

Notice (Other)

Aug. 9, 2002

Aug. 9, 2002

PACER
53

Notice (Other)

Aug. 9, 2002

Aug. 9, 2002

PACER
54

Miscellaneous Document

Aug. 19, 2002

Aug. 19, 2002

PACER
55

Order on Motion for Miscellaneous Relief

Oct. 9, 2002

Oct. 9, 2002

PACER
56

Motion to Cite Authority

Oct. 11, 2002

Oct. 11, 2002

PACER
57

Response to Motion

Oct. 15, 2002

Oct. 15, 2002

PACER

Order

Oct. 16, 2002

Oct. 16, 2002

PACER
58

Motion to Compel

Oct. 16, 2002

Oct. 16, 2002

PACER

Order

Oct. 17, 2002

Oct. 17, 2002

PACER

Order

Oct. 21, 2002

Oct. 21, 2002

PACER
59

Motion for Extension of Time to File

Oct. 21, 2002

Oct. 21, 2002

PACER
60

Report and Recommendations

Oct. 31, 2002

Oct. 31, 2002

PACER
61

Response to Motion

Nov. 1, 2002

Nov. 1, 2002

PACER

Order

Nov. 8, 2002

Nov. 8, 2002

PACER
62

Motion for Order

Nov. 8, 2002

Nov. 8, 2002

PACER
63

Motion for Extension of Time to File

Nov. 13, 2002

Nov. 13, 2002

PACER

Order

Nov. 14, 2002

Nov. 14, 2002

PACER
64

Motion for Extension of Time to File

Nov. 14, 2002

Nov. 14, 2002

PACER
65

Motion for Extension of Time to File

Nov. 14, 2002

Nov. 14, 2002

PACER

Order

Nov. 15, 2002

Nov. 15, 2002

PACER
66

Response to Motion

Nov. 20, 2002

Nov. 20, 2002

PACER
67

Objection to Report and Recommendations

Nov. 22, 2002

Nov. 22, 2002

PACER
68

Objection to Report and Recommendations

Nov. 22, 2002

Nov. 22, 2002

PACER

Minutes - Miscellaneous

Nov. 25, 2002

Nov. 25, 2002

PACER
69

Response

Dec. 9, 2002

Dec. 9, 2002

PACER
70

Order

Jan. 8, 2003

Jan. 8, 2003

PACER
72

Amended Complaint

Jan. 8, 2003

Jan. 8, 2003

PACER
71

Answer - Miscellaneous

Jan. 27, 2003

Jan. 27, 2003

PACER

Order

Feb. 10, 2003

Feb. 10, 2003

PACER
73

Order

Feb. 12, 2003

Feb. 12, 2003

PACER
74

Affidavit

Feb. 21, 2003

Feb. 21, 2003

PACER
75

Motion for Extension of Time to File

Feb. 21, 2003

Feb. 21, 2003

PACER
76

Motion for Leave to File

Feb. 21, 2003

Feb. 21, 2003

PACER

Order

Feb. 24, 2003

Feb. 24, 2003

PACER
77

Answer - Miscellaneous

Feb. 24, 2003

Feb. 24, 2003

PACER
78

Motion for Miscellaneous Relief

March 27, 2003

March 27, 2003

PACER
79

Order

April 16, 2003

April 16, 2003

PACER
80

Order

April 17, 2003

April 17, 2003

PACER
81

Affidavit

April 23, 2003

April 23, 2003

PACER
82

Notice (Other)

May 6, 2003

May 6, 2003

PACER

Case Details

State / Territory: Illinois

Case Type(s):

Equal Employment

Key Dates

Filing Date: Jan. 28, 2002

Closing Date: 2005

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Three current and former employees of Rent-A-Center, Inc. who were not promoted after taking the required tests, including one for psychiatric assessment, on behalf of all past and present RAC employees in Illinois who took the tests.

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Rent-A-Center Incorporated, Private Entity/Person

Associated Personnel Technicians, Private Entity/Person

Defendant Type(s):

Retailer

Case Details

Causes of Action:

Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.

State law

Available Documents:

Trial Court Docket

Monetary Relief

Injunctive (or Injunctive-like) Relief

Non-settlement Outcome

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Attorneys fees

Damages

Source of Relief:

Litigation

Content of Injunction:

Other requirements regarding hiring, promotion, retention

Amount Defendant Pays: $160,328.85

Order Duration: 2005 - 2005

Issues

General/Misc.:

Record-keeping

Retaliation

Staff (number, training, qualifications, wages)

Testing

Test or device

Disability and Disability Rights:

Mental Illness, Unspecified

Mental impairment

Discrimination Basis:

Disability (inc. reasonable accommodations)

Discrimination Area:

Discharge / Constructive Discharge / Layoff

Medical Exam / Inquiry

Promotion

Testing