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Constitutional Law Keyed to Choper
Logan v. Zimmerman Brush Co.
Citation:
455 U.S. 422 (1982)Facts
Laverne Logan was hired as a shipping clerk by Zimmerman Brush Company but was discharged after one month, allegedly because his short left leg made it impossible for him to perform his duties. Logan filed a timely discrimination charge with the Illinois Fair Employment Practices Commission, claiming unlawful termination based on physical handicap. Under Illinois law, the Commission was required to convene a factfinding conference within 120 days of the filing. However, the Commission inadvertently scheduled the conference for five days after the statutory deadline. When the conference date arrived, Zimmerman moved to dismiss the charge based on the Commission’s failure to meet the deadline. The Illinois Supreme Court ultimately held that the 120-day requirement was mandatory and jurisdictional, and that the Commission’s failure to comply deprived it of jurisdiction to hear Logan’s claim. The court rejected Logan’s due process and equal protection arguments, ruling that the legislature could establish reasonable procedures for discrimination claims.
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