Task: Wrong Candidate Generation
Input (English): Our research has revealed a number of cases in which Illinois courts have considered whether the terms of section 4(h) of the Act support the implication of a statutory right of action for retaliatory conduct apart from actual discharge of the employee. See Bryce v. Johnson & Johnson (1983), 115 Ill. App. 3d 913 (plaintiff who was reassigned to a position at half his salary failed to state cause of action for violation of section 4(h) because he was not discharged); Bragado v. Cherry Electrical Products Corp. (1989), 191 Ill. App. 3d 136 (plaintiffs claim for wrongful termination of temporary total disability benefits was a matter for the Industrial Commission and not the basis for an action pursuant to section 4(h)); Cook v. Optimum/ Ideal Managers Inc. (1984), 130 Ill. App. 3d 180 (<HOLDING>); Miranda v. Jewel Cos. (1989), 192 Ill. App. 
 Holding statements: (A) holding that because of statutory remedial scheme court would not imply a cause of action arising directly under the state constitution (B) holding that court would not imply a statutory cause of action for employers interference in employees assertion of claim for compensation (C) holding that court would not imply a bivens cause of action for a prisoner held in a private prison facility (D) recognizing cause of action (E) holding that dismissal is proper for a derivative cause of action but not for a direct cause of action
Output (English): holding that dismissal is proper for a derivative cause of action but not for a direct cause of action