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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

WESTERN DIVISION

Pierre G. Thorsen,

Plaintiff,

v.

Community Unit School District 300, and 

Local Education Association District 300,

Defendants.

Case No. 3:20-cv-50132

Judge Iain D. Johnston

Magistrate Judge Margaret Schneider 

THIRD AMENDED COMPLAINT 

Now comes Plaintiff, PIERRE G. THORSEN, by his attorneys, Hanson Law Group, LLP, 

and for his Third Amended Complaint against Defendants, COMMUNITY UNIT SCHOOL 

DISTRICT 300 and LOCAL EDUCATION ASSOCIATION DISTRICT 300, states as follows:

COUNT I AGAINST CUSD 300

EMPLOYMENT DISCRIMINATION IN VIOLATION OF

TITLE VII OF THE CIVIL RIGHTS ACT OF 1964

PARTIES

1. This is an action for employment discrimination, brought by the plaintiff, Pierre G.

Thorsen, a resident of the County of Kane in the State of Illinois. This Third Amended Complaint 

follows the filing of an original Complaint and an Amended Complaint. 

2. The defendant is Community Unit School District 300, (CUSD 300), with an

administrative headquarters of 2550 Harnish Drive, Algonquin, Illinois 60102, in McHenry 

County.

JURISDICTIONAL GROUNDS

3. Thorsen was employed by CUSD 300, with McHenry County headquarters. CUSD

300 includes students residing in Kane, Cook, DeKalb, and McHenry counties. He taught at Jacobs 

EXHIBIT A

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High School, 2601 Bunker Hill Road, Algonquin, Illinois 60102 in McHenry County, and at 

Hampshire High School, 1600 Big Timber Road, Hampshire, Illinois 60140, in Kane County.

4. Starting on August 26, 1996, the plaintiff was employed continuously by the

defendant, until a forced resignation and/or constructive termination occurred at the McHenry 

County District 300 headquarters on August 23, 2019.

5. The forced resignation and/or constructive termination was effective

September 3, 2019.

6. The defendant discriminated against the plaintiff, beginning on or about,

April 2017.

7. The defendant is not a federal government agency, and the plaintiff has filed 

charges against the defendant asserting the acts of discrimination indicated in this complaint with 

the United States Equal Employment Opportunity Commission, on or about, January 14, 2020. A 

copy of the charge is attached to the original complaint as Exhibit A [DKT #1-1], and incorporated 

by reference herein as Exhibit A. It is the policy of both the Equal Employment Opportunity 

Commission and the Illinois Department of Human Rights to cross-file with the other agency all

charges received. The plaintiff has no reason to believe that this policy was not followed in this 

case.

8. The United States Equal Employment Opportunity Commission has issued a Notice

of Right to Sue, mailed January 15, 2020, which was received by the plaintiff in the regular U. S. 

mail no sooner than January 17, 2020, a copy of which is attached to the amended complaint as 

Exhibit B [DKT #33-1] and incorporated by reference herein as Exhibit B. The original Complaint 

was filed within 90 days of that receipt.

9. The defendant discriminated against the plaintiff because of the plaintiff’s religion.

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10. Jurisdiction over the statutory violation alleged is conferred for Title VII claims by

28 U.S.C.§1331, 28 U.S.C.§1343(a)(3), and 42 U.S.C.§2000e-5(f)(3).

STATEMENT OF THE CLAIM SHOWING ENTITLEMENT TO RELIEF

11. Plaintiff observes and practices the religion of Christianity, and, thus, is a member 

of a protected class.

12. The defendant retaliated against the plaintiff because the plaintiff did something to

assert rights protected by the laws identified in paragraphs 9 and 10.

13. Plaintiff performed reasonably on the job in accord with his employer’s legitimate 

expectations, since 1996, by the following:

a. In a legitimate pedagogical way, asked students the historical origins of their last 

names, with no reference to culture, religion, or race, complying with 105 ILCS 5/27-21, 

which provides in relevant part, that when teaching U.S. History, the teaching,

... shall include a study of the role and contributions of African Americans 

and other ethnic groups including but not restricted to Polish, Lithuanian,

German, Hungarian, Irish, Bohemian, Russian, Albanian, Italian, Czech, 

Slovak, French, Scots, Hispanics, Asian Americans, etc., in the history of 

this country and this State ....

b. In a legitimate, pedagogical way, answered questions from students concerning 

secular objects in the classroom and how they relate to historical events involving 

Christians in the Roman Empire, and being willing to die for beliefs, complying with 105

ILCS 5/27-12, which requires that every public school teacher shall teach character 

education, to raise pupils’ “moral courage,” and 105 ILCS 5/27-20.3, which requires 

curriculum to include lessons of the Holocaust and “other acts of genocide across the 

globe.”

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c. In a legitimate, pedagogical way, asked an entire Academic Support Period 

classroom icebreaker, introductory questions about historical origins of last names, to 

improve the learning environment, complying with 105 ILCS 5/27-21, which provides in 

relevant part, that when teaching U.S. History, the teaching,

... shall include a study of the role and contributions of African Americans 

and other ethnic groups including but not restricted to Polish, Lithuanian,

German, Hungarian, Irish, Bohemian, Russian, Albanian, Italian, Czech, 

Slovak, French, Scots, Hispanics, Asian Americans, etc., in the history of 

this country and this State ....

d. In a legitimate, and pedagogical way, during an Academic Support Period, 

answered student questions to provide academic support, using a part of District 

curriculum, as a teacher the District made available to students to provide extra academic 

support (See Exhibit C, and Exhibit D2 attached to the amended complaint [DKT #33-1], 

and incorporated by reference herein as Exhibit C, and Exhibit D2).

e. Received the honor, in 2015, of being nominated for “Kane County Educator of the 

Year,” by the District.

f. Received support from the District’s residents for his teaching. (See Group Exhibit 

E attached to the amended complaint [DKT #33-1], and incorporated by reference herein as 

Group Exhibit E.)

g. Prior to 2017, received numerous high ratings and commendations for teaching

performance by the District, and even since 2017, never received a formal review of less 

than proficient.

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14. Despite his reasonable performance, he was subjected to adverse employment 

action as follows:

a. Defendant unduly restricted use of the term, inter alia, “bless you, my child.”

b. Defendant otherwise created a hostile environment, intolerable conditions, and 

undue restrictions against Christianity. (See April, 16 2019, Notice to Remedy, attached 

hereto, and incorporated by reference herein as Exhibit F.)

c. Following the actions described in paragraphs 13 a-d, in August 2019, defendant 

told plaintiff, during what was represented to him as a fact-finding meeting, that because 

his talk of Christianity and religion made people uncomfortable, and for his actions

described in paragraphs 13 a-d, his firing/termination for alleged just cause was imminent, 

(which would make it extremely difficult to find similar work).

d. Essentially, the District representatives present at the purported factfinding meeting 

materially misrepresented facts to plaintiff, telling him that he would be terminated, 

although there had been no school board meeting.

e. The District then told Plaintiff, through his union representatives, that unless he 

resigned that day, prior to leaving the purported “fact finding” meeting at the district 

headquarters he would be fired for just cause (making finding similar works extremely 

difficult).

15. Under duress, Thorsen did and was forced to resign prior to leaving that meeting

room, and was constructively terminated, which caused substantial loss of pay and future pension 

benefits.

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16. Similarly situated employees outside of his protected class were treated more

favorably, as shown below.

a. Religion of the ancient Greeks was taught as a part of the District curriculum, with 

no adverse action against the teacher.

b. Atheism and agnosticism were advocated, without adverse action against the 

teacher.

c. Activities involving getting to know your name were taught, including historical 

background, without adverse action against the teacher.

17. The plaintiff demands that the case be tried by a jury.

DEMAND FOR RELIEF

WHEREFORE, the plaintiff asks that the court grant the following relief to the plaintiff:

a. Direct the defendant to re-employ the plaintiff.

b. Direct the defendant to reasonably accommodate the plaintiff’s religion and

cease intolerable and hostile conditions.

c. Direct the defendant to pay lost wages and compensatory damages, in an amount in

excess of $75,000.00.

d. Grant the plaintiff appropriate injunctive relief, lost wages, compensatory damages, 

post- judgment interest, and costs, including reasonable attorney fees and expert witness fees.

e. Grant such other relief as the Court may find appropriate.

COUNT II AGAINST CUSD 300

INDUCEMENT OF BREACH OF FIDUCIARY DUTY

PARTIES AND JURISDICTIONAL GROUNDS

18-34. Plaintiff incorporates herein by reference, the allegations in paragraphs 1-17, as 

paragraphs 18-34 herein.

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35. Local Education Association District 300 (LEAD 300) was the union representing 

Pierre Thorsen during his time as a teacher at CUSD 300. LEAD 300 has an address of 2250 Point 

Boulevard, Elgin, Illinois, 60123. 

STATEMENT OF THE CLAIM SHOWING ENTITLEMENT TO RELIEF

36. LEAD 300 had a fiduciary duty to act in the best interest of Pierre Thorsen, who 

was a dues-paying member of LEAD 300. CUSD 300 colluded with LEAD 300 to breach its 

fiduciary duty to Pierre Thorsen, and induced or participated in such breaches, as follows: 

a. After LEAD 300 provided attorney representation as a union benefit to Pierre 

Thorsen at a disciplinary meeting in April 2019, from which the above April, 2019, Notice 

to Remedy was issued (but Pierre Thorsen kept his job), CUSD 300 through its in-house 

attorney, met with Pierre Thorsen, LEAD 300 representatives, and CUSD 300 

representatives, to coerce and force Pierre Thorsen to resign; 

b. In August 2019, CUSD 300 allowed its in-house attorney to discuss the alleged 

violation of the Notice to Remedy, without Pierre Thorsen having an attorney present at 

the discussion to act in the best interest of Pierre Thorsen; having an attorney present would 

have prevented the coerced and forced resignation; and

c. In addition, CUSD 300 showed its tendency to plot with LEAD 300 as early as 

February 19, 2019, to the detriment of Pierre Thorsen by:

i. Ambushing Pierre Thorsen at a fact-finding meeting with new allegations, so 

that Pierre Thorsen could not have time to present a defense; and 

ii. Advising LEAD 300 (but not Pierre Thorsen) of the ambush. Pierre Thorsen 

did not receive notice and thus was ambushed. CUSD 300 presented new but 

false allegations to Pierre Thorsen with no prior warning from CUSD 300 nor 

LEAD 300. (See Exhibit G, attached hereto and incorporated herein.) 

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37. CUSD 300 obtained the benefit of this breach of fiduciary duty by LEAD 300, as 

CUSD 300 obtained the forced resignation of Pierre Thorsen, which was the objective of 

CUSD 300.

DEMAND FOR RELIEF

WHEREFORE, the plaintiff asks that the court grant the following relief to the plaintiff:

a. Direct the defendant to re-employ the plaintiff.

b. Direct the defendant to reasonably accommodate the plaintiff’s religion and

cease intolerable and hostile conditions.

c. Direct the defendant to pay lost wages and compensatory damages, in an amount in

excess of $75,000.00.

d. Grant the plaintiff appropriate injunctive relief, lost wages, compensatory damages, 

post- judgment interest, and costs, including reasonable attorney fees and expert witness fees.

e. Grant such other relief as the Court may find appropriate.

COUNT III AGAINST CUSD 300

CIVIL CONSPIRACY

38-74. Pierre Thorsen adopts hereto and incorporates herein paragraphs 1-37 as paragraphs 

38-74 herein. 

75. As early as February 15, 2019, CUSD 300 plotted with LEAD 300, to harm Pierre 

Thorsen. 

76. CUSD 300 plotted with LEAD 300 to harm Pierre Thorsen by: 

a. Ambushing Pierre Thorsen at a fact-finding meeting with new allegations, so that 

Pierre Thorsen could not have time to present a defense; 

b. Advising LEAD 300 (but not Pierre Thorsen) of the ambush to avoid violating due 

process provisions of the Union-CUSD 300 contract, and in fact did present these new, but 

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false allegations to Pierre Thorsen with no prior warning from CUSD 300 nor LEAD 300. 

(See Exhibit G, attached hereto and incorporated herein.) 

77. Continuing on with this plot, as set forth above in paragraph 36, a-b, CUSD 300 

acted in an unlawful manner. 

78. As a direct and proximate result of this civil conspiracy, Pierre Thorsen submitted

an immediate and a forced resignation, causing a substantial loss of income and benefits. 

DEMAND FOR RELIEF

WHEREFORE, the plaintiff asks that the court grant the following relief to the plaintiff:

a. Direct the defendant to pay lost wages and compensatory damages, in an amount in 

excess of $75,000.00.

b. Grant the plaintiff appropriate injunctive relief, lost wages, compensatory damages,

post- judgment interest, and costs, including reasonable attorney fees and expert witness fees.

c. Grant such other relief as the Court may find appropriate.

COUNT IV AGAINST LEAD 300

BREACH OF FIDUCIARY DUTY

79. Pierre Thorsen adopts and incorporates herein paragraphs 1-78 as paragraphs 79-

157 herein.

STATEMENT OF THE CLAIM SHOWING ENTITLEMENT TO RELIEF

80. In 2019 and for over ten years prior thereto, LEAD 300 was a teacher’s union in 

which Pierre Thorsen was a dues paying member. 

81. At all times described herein, LEAD 300 had a fiduciary duty to act in the best 

interest of Pierre Thorsen. 

82. As a part of that fiduciary duty, LEAD 300, as a union benefit, provided Pierre 

Thorsen with attorney representation at a disciplinary meeting in April 2019.

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83. The in-house attorney for CUSD 300 was present at that meeting.

84. Although a Notice to Remedy was served as a result of that meeting, Pierre Thorsen 

kept his job.

85. In August 2019, LEAD 300 was advised of a “fact-finding” meeting to be 

conducted by CUSD 300, concerning an alleged violation of the Notice to Remedy, but failed to

provide attorney consultation in preparation for that meeting or attorney protection at that meeting.

86. As a direct and proximate result of that failure to have an attorney present to protect 

Pierre Thorsen, Thorsen communicated with the in-house CUSD 300 attorney and was persuaded 

to submit an immediate and forced resignation. 

87. This forced resignation has and will cost Pierre Thorsen significant monetary 

damages. 

DEMAND FOR RELIEF

WHEREFORE, the plaintiff asks that the court grant the following relief to the plaintiff:

a. Direct the defendant to pay lost wages and compensatory damages, in an amount in

excess of $75,000.00.

b. Grant the plaintiff appropriate injunctive relief, lost wages, compensatory damages, 

post- judgment interest, and costs, including reasonable attorney fees and expert witness fees.

c. Grant such other relief as the Court may find appropriate.

COUNT V LEAD 300

CIVIL CONSPIRACY AGAINST 

88-175. Pierre Thorsen adopts and incorporates herein paragraphs 1-87 as paragraphs 88-

175 herein. 

176. As set forth in paragraphs 75-77 above, LEAD 300 was predisposed to colluding 

with CUSD 300, and acting against the best interest of Pierre Thorsen.

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177. Additionally, LEAD 300 destroyed evidence of the pretextual grading issue being 

presented by CUSD 300. (See Exhibit H, attached hereto and incorporated herein.)

178. As set forth in paragraphs 80-87 above, LEAD 300, by failing to call an attorney to 

be present to protect Pierre Thorsen, caused Pierre Thorsen to submit to an immediate and forced 

resignation. 

179. As a direct and proximate result of the above failure, Pierre Thorsen has sustained 

substantial monetary losses. 

DEMAND FOR RELIEF 

WHEREFORE, the plaintiff asks that the court grant the following relief to the plaintiff:

a. Direct the defendant to pay lost wages and compensatory damages, in an amount in 

excess of $75,000.00.

b. Grant the plaintiff appropriate injunctive relief, lost wages, compensatory damages, 

post- judgment interest, and costs, including reasonable attorney fees and expert witness fees.

c. Grant such other relief as the Court may find appropriate.

Dated this day: November 10, 2022 Respectfully Submitted, 

/s/ Timothy J. Lowery 

Timothy J. Lowery

Attorney for Plaintiff

Hanson Law Group, LLP

1000 Hart Road, Suite 300 

Barrington, IL 60010 

Main: (847) 277 – 9988 

Fax: (847) 277 – 7339 

timlowery@hansonlawgrp.com; 

keithhanson@hansonlawgrp.com

nancymondragon@hansonlawgrp.com;

kaitlynlancaster@hansonlawgrp.com

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EXHIBIT F



EXHIBIT G
EXHIBIT H