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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

EQUAL EMPLOYMENT OPPORTUNITY ) 

COMMISSION, ) 

 Plaintiff, ) Civil Action No. 1:20-CV-03579 

 ) 

v. ) Judge Robert M. Dow Jr. 

 ) 

VHS WEST SUBURBAN ) 

MEDICAL CENTER, LLC and ) 

PIPELINE-WEST SUBURBAN ) 

MEDICAL CENTER, LLC, ) 

 Defendants. ) 

CONSENT DECREE

THE LITIGATION 

1. Plaintiff U.S. Equal Employment Opportunity Commission (“EEOC”) filed a 

Complaint under Title I of the Americans with Disabilities Act of 1990 (“ADA”) and Title I of 

the Civil Rights Act of 1991 against Defendant Tenet Healthcare Corporation (“Tenet”) alleging 

that Tenet violated the ADA when it failed to provide Maribel Quiroz (“Quiroz”) a reasonable 

accommodation in January 2016, failed to permit her to return to work in April 2016 because of 

her disability, and discharged her in July 2016 because of her disability. 

2. EEOC also filed this suit against Pipeline-West Suburban Medical Center, LLC 

(“Pipeline”) alleging that Pipeline is a successor to Tenet for all purposes related to this action. 

EEOC does not allege that Pipeline engaged in discriminatory conduct against Maribel Quiroz. 

Defendants filed answers denying the material allegations of EEOC’s complaint. 

3. Tenet filed a motion stating that VHS West Suburban Medical Center, LLC 

(“VHS”) was Quiroz’s employer within the meaning of the ADA at the times of the occurrences 

referenced in the Complaint and is the proper defendant in this action. Tenet was granted leave 

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to amend its answer to denying that it was Quiroz’s employer. Thereafter, VHS has voluntarily 

participated in the resolution of this matter and agreed to be bound by the terms of this Consent 

Decree. The EEOC, Tenet, VHS, and Pipeline agree — and the court hereby orders — that Tenet 

is substituted for VHS as a Defendant in this matter. Tenet is bound by this Decree only to the 

extent specifically set forth below. In this Decree, “Defendants” refers to VHS and Pipeline. 

4. In the interest of resolving this matter, and as a result of having engaged in 

comprehensive settlement negotiations, Plaintiff and Defendants have agreed that this action 

should be fully and finally resolved by entry of this Consent Decree (“Decree”). 

5. This Decree fully and finally resolves any and all issues and claims arising out of 

the Complaint filed by the Plaintiff and shall be binding on the Plaintiff; Defendants; 

Defendants’ respective directors, officers, employees, successors, and assigns; and all persons in 

active concert or participation with Defendants. 

6. Notwithstanding the foregoing, the parties to this Decree acknowledge and agree 

that it applies to: (a) Pipeline only to the extent set forth in Paragraphs 8-10 and 26-30, below, 

but does not otherwise impose any further obligations on Pipeline; and (b) Tenet and its 

directors, officers, employees, successors and assigns to the extent set forth in Paragraphs 8 and 

9 below, but does not otherwise impose any further obligations on Tenet. 

FINDINGS 

7. Having carefully examined the terms and provisions of this Decree, and based on 

the pleadings, record, and stipulations of the parties, the Court finds that: 

(a) This Court has jurisdiction over the subject matter of this action and the 

parties hereto; 

(b) The terms of this Decree are adequate, fair, reasonable, equitable, and just; 

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(c) The rights of the parties and the public are adequately protected by this 

Decree; 

(d) This Decree conforms to the Federal Rules of Civil Procedure, the ADA, and 

is not in derogation of the rights or privileges of any person; and 

(e) Entry of this Decree will further the objectives of the ADA and will be in the 

best interests of the parties and the public. 

NOW, THEREFORE, IT IS ORDERED, ADJUDGED, AND DECREED THAT: 

MONETARY RELIEF 

8. Within seven (7) calendar days of the later of entry of this Decree by the Court 

and receipt by Defendants of the Release attached as Exhibit A signed by Quiroz, Tenet or VHS 

shall pay Quiroz the gross sum of $150,000, for which they are jointly and severally liable. Of 

the gross sum, $75,000 shall be designated as back wages. The amount designated as back wages 

shall be subject to any required tax withholdings and deductions, for which Tenet and/or VHS 

shall issue an IRS Form W-2 to Quiroz. Tenet or VHS may not deduct the employer’s share of 

applicable taxes from the amount to be paid to Quiroz. Tenet or VHS shall issue an IRS Form 

1099 to Quiroz for the remainder of damages. No deductions shall be made with respect to the 

remaining amount designated as compensatory damages. Tenet or VHS shall send Quiroz 

payment by check via Certified or Registered Mail or, if requested by EEOC, via electronic 

deposit. Contemporaneously, Tenet or VHS shall submit a copy of the check(s) to EEOC or a 

receipt or other record showing the electronic deposit. 

9. If any portion of the monetary relief is not issued and mailed to Quiroz within the 

seven (7) day period set forth in Paragraph 8 (“Unpaid Amount”), then for each business day 

beyond that period that the Unpaid Amount remains unpaid, Tenet or VHS shall pay to Quiroz, 

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in the manner set forth above, an amount equal to the greater of $50 or 0.1% of the Unpaid 

Amount. Pipeline is jointly and severally liable for payment to Quiroz of all monetary relief 

owed by Tenet and VHS, and EEOC may seek any proportion of the Unpaid Amount, and any 

additional amount as described in this paragraph, from any of the Defendants and/or Tenet. 

INJUNCTION AGAINST RETALIATION 

10. Pipeline and VHS, their directors, officers, agents, employees, successors, 

assigns, and all persons acting in concert with them are hereby enjoined from engaging in any 

form of retaliation against any person because such person has opposed any practice made 

unlawful under the ADA; filed a Charge of Discrimination under the ADA; testified or 

participated in any manner in any investigation, proceeding, or hearing under the ADA; or 

asserted any rights under this Decree. 

VHS 

11. VHS hereby certifies to the Court and to EEOC that it does not own and operate 

any business with facilities in Illinois. 

12. VHS shall provide the EEOC with semi-annual written certifications through the 

duration of the Decree that it has not assumed ownership or operations of any business with 

facilities in Illinois. The first such certification shall be due 6 (six) months after entry of the 

Decree. 

13. If VHS assumes ownership or operation of a business with a facility in Illinois 

(Covered Facility) during the duration of this Decree, it shall notify EEOC no later than 30 days 

in advance, and shall be bound by the provisions of this Decree contained in Paragraphs 14-25 

below, without further act or deed by any person and without further notice to or order from the 

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Court. Otherwise, VHS shall not be bound by the provisions of this Decree contained in 

Paragraphs 14-25 below. 

INJUNCTION AGAINST DISCRIMINATION 

14. VHS, its directors, officers, agents, employees, successors, assigns, and all 

persons acting in concert with them are hereby enjoined from: (1) discharging or failing to allow 

any employee to return to work from a leave of absence on the basis of disability at a Covered 

Facility; and (2) failing to provide reasonable accommodations in violation of the ADA at a 

Covered Facility. 

DISABILITY DISCRIMINATION AND ACCOMMODATION POLICIES 

15. Within thirty (30) calendar days of VHS assuming ownership or operation of a 

Covered Facility, VHS shall adopt or affirm, and maintain throughout the Term of this Decree, 

policies at the Covered Facility related to reasonable accommodations and disability 

discrimination. Such policies shall, at minimum: 

(a) Specifically prohibit each form of employment discrimination that is unlawful 

under the ADA 

(b) State that employees who need a reasonable accommodation for a disability 

may request one, and provide examples of how employees may make such 

requests and examples of reasonable accommodations including an example 

of a restructured job, an altered schedule, an assistive device, an 

environmental alteration, and a transfer to a comparable open position. 

(c) State that upon learning of an employee’s possible need for accommodation of 

a disability, VHS will promptly engage the employee in an interactive process 

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to evaluate what accommodation(s) may be needed to enable the employee to 

perform his or her essential job functions. 

(d) State that VHS will not categorically apply any “100% healed,” “released to 

full duty,” or “released without restrictions,” requirements to employees, 

including employees seeking to return from any disability-related absence, 

and that VHS will instead give individualized consideration to an employee’s 

ability to perform the essential functions of his or her job, with or without a 

reasonable accommodation. 

(e) State that when an employee makes a request for an accommodation, VHS 

will communicate, in writing, what reasonable accommodation(s) it will 

provide or, if VHS determines that it cannot provide a reasonable 

accommodation, the basis for that decision, including the possible reasonable 

accommodations considered. 

16. Nothing in this Decree represents an endorsement by the EEOC or by the Court 

that VHS or any of its policies have been or is in compliance with federal anti-discrimination 

laws. 

TRAINING 

17. No later than sixty (60) calendar days after VHS assumes ownership or operation 

of a Covered Facility, all of VHS’s human resources and supervisory employees at the Covered 

Facility shall participate in a training session regarding the laws pertaining to employment 

discrimination, including obligations of employers under the ADA. VHS shall repeat this 

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training at least once every twelve (12) months for the duration of the Decree. A registry of 

attendance shall be maintained for each training session required under this paragraph. 

18. VHS shall obtain the EEOC’s approval of its proposed trainer and the content the 

trainer proposes to present before the commencement of any training session required under 

Paragraph 17, above. The trainer shall not be: (a) an individual who provided legal representation 

or advice to (or who is affiliated with an entity that has provided legal representation or advice 

to) Defendants, VHS or any of their owners, officers, or management employees during or 

subsequent to the five years preceding entry of this Decree; or (b) an owner, officer, or employee 

of Defendants. VHS shall submit the name(s), address(es), telephone number(s), resume(s) and 

training proposal of their proposed trainer(s) (including copies of all materials proposed to be 

displayed, distributed, or otherwise presented) to the EEOC at least twenty (20) business days 

prior to the proposed date of each training session. EEOC shall have ten (10) business days from 

the date it receives the information described above to accept or reject the proposed trainer(s) 

and/or content the trainer proposes to present. In the event the EEOC does not approve VHS’s 

proposed trainer, training proposal, and/or training materials, VHS shall have five (5) business 

days to identify an alternate trainer and/or make changes to the training proposal and/or training 

materials. The EEOC shall then have five (5) business days from the date it receives the 

information described above to accept or reject the alternate trainer, proposal, and/or training 

materials. If the parties cannot agree on a trainer or training content through this process, they 

may seek the Court’s assistance under Paragraph 26, below. 

19. No later than five (5) business days after each training session described in 

Paragraph 15, above, takes place, VHS shall certify to the EEOC in writing that the required 

training session has taken place and the required personnel have attended. Every certification of 

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training described in this Paragraph shall include: (a) the date, location, and duration of the 

training; (b) a copy of the registry of attendance, which shall include the name and position of 

each person trained, including at which facility each person trained is employed; (c) a current list 

by name, position, and employer(s) of all the employees subject to the training requirement; and 

(d) copies of any and all pamphlets, brochures, outlines, or other written materials provided or 

displayed to the personnel attending each training session, if not already provided to the EEOC. 

POSTING AND DISTRIBUTION OF NOTICE 

20. No later than ten (10) business days after VHS assumes ownership or operation of 

a Covered Facility, VHS shall post copies of the Notice attached as Exhibit B to this Decree in 

physical or electronic locations that are regularly used by VHS for posting legal notices 

concerning employee rights at the Covered Facilities. The Notices shall remain posted in this 

manner for the term of this Decree. VHS shall take all reasonable steps to ensure that the 

postings are not altered, defaced, or covered by any other material. VHS shall permit a 

representative of the EEOC to enter its premises for purposes of verifying compliance with this 

Paragraph at any time during normal business hours without prior notice. 

21. No later than fifteen (15) business days after VHS assumes ownership or 

operation of a Covered Facility, VHS shall certify to EEOC in writing that the Notices have been 

properly posted and distributed in accordance with Paragraph 20. 

RECORD KEEPING 

22. VHS shall maintain and make available for inspection and copying by the EEOC 

written records of every complaint or report of disability discrimination and each request for a 

reasonable accommodation at all of its Covered Facilities, if any. 

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23. For each such complaint or report of disability discrimination, such records shall 

include: (a) the name of the employee who made the complaint or report and that employee’s 

address and telephone number; (b) the date of the complaint or report; (c) a written description of 

what was alleged; (d) the name and position of all employees who were made aware of the 

complaint or report; (e) a written description of the resolution or outcome, including a 

description of what actions, if any, VHS took, and the name and position of all employees who 

were involved in any such actions taken; (f) if the complaint or report was made in written form, 

a copy thereof; and (g) a copy of all documents, including notes, correspondence, photographs, 

or written statements, collected in the course of the investigation. 

24. For each request for a reasonable accommodation, such records shall include: (a) 

the name, address, and telephone number of the employee making the request; (b) the date of the 

request; (c) the functions of the employee’s position that the employee is requesting to have 

accommodated; (d) a description of any specific accommodation(s) requested or suggested by 

the employee; (e) the name and position of all employees who were made aware of the request 

for accommodation; (f) a written description of the resolution or outcome of the request, 

including whether an accommodation was provided and if so, what accommodation was 

provided; if no accommodation was provided, the reason why VHS determined that it could not 

provide an accommodation; and the name and position of all employees who were involved in 

any determining whether an accommodation should be made; (e) if the request for an 

accommodation is in written form, a copy thereof; and (d) a copy of all documents, including 

notes, correspondence, doctor’s notes, or written statements, collected in the course of deciding 

whether to provide an accommodation. 

REPORTING 

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25. VHS shall furnish to the EEOC the following written reports semi-annually 

(“Semi-Annual Report”), to the extent applicable, during the term of this Decree. The first SemiAnnual Report shall be due six (6) months after VHS assumes ownership or operation of a 

Covered Facility. Subsequent Semi-Annual Reports shall be due every six (6) months thereafter, 

except that the final Semi-Annual Report shall be due thirty (30) calendar days prior to the 

expiration of the Decree. Each such Semi-Annual Report shall contain: 

(a) copies of all records described in Paragraph 22-24, above, for the six (6) month 

period preceding the Semi-Annual Report (or for the five (5) month period 

preceding the final Semi-Annual Report), or a certification by VHS that no 

complaints or reports of disability discrimination or requests for reasonable 

accommodations were received during that period; and 

(b) a certification by VHS that the Notice required to be posted pursuant to Paragraph 

20 of the Decree remained posted in the manner required during the entire six (6) 

month period preceding the Semi-Annual Report (or for the five (5) month period 

preceding the final Semi-Annual Report). 

DISPUTE RESOLUTION 

26. If EEOC, during the term of this Decree, believes that any Defendant has failed to 

comply with any provision(s) of the Decree, EEOC shall notify that Defendant of the alleged 

noncompliance and shall afford the party ten (10) business days to remedy the noncompliance or 

satisfy EEOC that the party has complied. If within ten (10) business days the party has not 

remedied the alleged noncompliance or satisfied EEOC that they have complied, EEOC may 

apply directly to the Court for relief. In resolving any dispute under this Paragraph, if the Court 

finds noncompliance by a preponderance of the evidence, the Court may grant any relief it 

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determines to be appropriate, which may include modification of the Term or any other provision 

of this Decree, monetary sanctions, and/or any appropriate relief available to a court of equity. 

TERM AND SCOPE OF THE DECREE AND RETENTION OF JURISDICTION 

27. This Decree shall be in effect (and the Court will retain jurisdiction of this matter 

to enforce this Decree) for a term of four (4) years immediately following the entry of the 

Decree, unless extended by order of this Court, provided, however, that if at the end of the term 

of the Decree, any disputes under Paragraph 26, above, remain unresolved, the term of the 

Decree shall be automatically extended (and the Court will retain jurisdiction of this matter to 

enforce the Decree) until such time as all such disputes have been resolved. 

MISCELLANEOUS PROVISIONS 

28. Each party to this Decree shall bear its own expenses, attorneys’ fees, and costs, 

except as otherwise indicated in this Decree, and except as otherwise agreed in writing by any of 

the parties. 

29. Defendants shall not condition the receipt of monetary relief on the agreement of 

Quiroz to: (a) waive any statutory rights to file a charge with any governmental agency; or (b) 

enter into a non-disparagement or confidentiality agreement. 

30. The terms of this Decree are and shall be binding on the present and future 

directors, officers, managers, agents, successors, and assigns of Pipeline and VHS during the 

duration thereof. Prior to any sale or other transfer of any Pipeline’s or VHS’ business or sale or 

other transfer of all or a substantial portion of their respective assets during the duration of this 

Decree, Pipeline and VHS shall provide a copy of this Decree to any potential purchaser, 

potential transferee, or other potential successor, except that this requirement shall cease to apply 

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to Pipeline once all monetary payments due under Paragraphs 8-9 of this Decree have been 

made. 

31. When this Decree requires a certification by any Defendant of any fact(s), such 

certification shall be made under oath or penalty of perjury by an officer or management 

employee of the Defendant to the best of such officer or management employee’s knowledge, 

information, and belief. 

32. VHS shall require personnel within their employ, upon request by the EEOC, to 

cooperate reasonably with, and to be interviewed by, the EEOC for purposes of verifying 

compliance with this Decree. 

33. When this Decree requires the submission by VHS of reports, certifications, 

notices, or other materials to the EEOC, they shall be sent by U.S. Mail to West Suburban 

Medical Center Consent Decree Compliance, Legal Unit, U.S. Equal Employment Opportunity 

Commission, 230 S. Dearborn St., Ste. 2920, Chicago, IL 60604. By advance agreement of the 

parties, prior to each submission, materials may alternatively be submitted by electronic mail. 

SO ORDERED, ADJUDGED, and DECREED on this ____ day of _______________ 2021. 

By the Court: 

 ________________________________________________ 

 The Hon. Robert M. Dow

 United States District Judge

________________________

Th H R b t M D

19th November

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Agreed to in form and content: 

For the EQUAL 

EMPLOYMENT 

OPPORTUNITY 

COMMISSION 

131 M. Street, NE 

Washington, DC 20507 

GWENDOLYN YOUNG 

REAMS 

Acting General Counsel 

_____________________ 

Gregory Gochanour 

EQUAL EMPLOYMENT 

OPPORTUNITY 

COMMISSION 

Chicago District Office 

230 S. Dearborn, Suite 2920 

Chicago, Illinois 60604 

Telephone: (312) 872-9685 

E-Mail: 

gregory.gochanour@eeoc.gov 

_____________________ 

Justin Mulaire 

EQUAL EMPLOYMENT 

OPPORTUNITY 

COMMISSION 

Chicago District Office 

230 S. Dearborn, Suite 2920 

Chicago, Illinois 60604 

Telephone: (312) 505-6384 

E-Mail: 

justin.mulaire@eeoc.gov 

________________ 

Ann M. Henry 

EQUAL EMPLOYMENT 

OPPORTUNITY 

COMMISSION 

Chicago District Office 

230 S. Dearborn, Suite 2920 

Chicago, Illinois 60604 

Telephone: (312) 872-9659 

E-Mail: ann.henry@eeoc.gov 

______________________ 

Jonathan Delozano 

EQUAL EMPLOYMENT 

OPPORTUNITY 

COMMISSION 

Chicago District Office 

230 S. Dearborn, Suite 2920 

Chicago, Illinois 60604 

Telephone: (312) 872-9695 

E-Mail: 

jonathan.delozano@eeoc.gov 

 

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For DEFENDANT PIPELINE WEST 

SUBURBAN MEDICAL CENTER, LLC 

________________________ 

Brittany Whitman 

Corporate Counsel 

For DEFENDANT VHS WEST 

SUBURBAN MEDICAL CENTER INC. 

_____________________ 

Marita Covarrubias 

Vice President/Assistant General Counsel 

Law Department 

For TENET HEALTHCARE INC. 

_______________________ 

Marita Covarrubias 

Vice President/Assistant General Counsel 

Law Department 

_____________________ 

Robert H. Smeltzer (ARDC No. 6208501) 

Walker Morton, LLP 

180 N. Stetson Avenue, 47th Floor 

Chicago, Illinois 60601 

(312) 471-2907 

rsmeltzer@walkermortonllp.com 

_____________________ 

Robert H. Smeltzer (ARDC No. 6208501) 

Walker Morton, LLP 

180 N. Stetson Avenue, 47th Floor 

Chicago, Illinois 60601 

(312) 471-2907 

rsmeltzer@walkermortonllp.com 

 

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EXHIBIT A

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RELEASE AGREEMENT

 In consideration of $150,000 to be paid to me by Defendants in connection with the 

resolution of EEOC v. VHS West Suburban Medical Center, LLC and Pipeline-West Suburban 

Medical Center, LLC, No. 20-cv-03579 (N.D. Ill.), I waive my right to recover for any claims of 

disability discrimination or failure to accommodate any disability arising under the Americans 

with Disabilities Act that I had against Defendants Pipeline-West Suburban Medical Center, 

LLC and VHS West Suburban Medical Center, LLC on or before the date of this release and that 

were included in the claims in EEOC’s complaint in EEOC v. VHS West Suburban Medical 

Center, LLC and Pipeline-West Suburban Medical Center, LLC, No. 20-cv-03579 (N.D. Ill.) 

Signed: _________________________ Date: ______________________ 

 Maribel Quiroz 

 

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EXHIBIT B

 

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NOTICE TO VHS EMPLOYEES

 This Notice is posted pursuant to a Consent Decree entered by the federal court in the 

Northern District of Illinois in EEOC v. VHS West Suburban Medical Center, LLC and Pipeline-West 

Suburban Medical Center, LLC, No. 20-cv-03579 (N.D. Ill.), resolving the lawsuit filed by the U.S. 

Equal Employment Opportunity Commission (EEOC) against Defendants VHS West Suburban 

Medical Center, LLC (VHS), and Pipeline-West Suburban Medical Center, LLC (Pipeline). 

 In this lawsuit, the EEOC alleged that VHS violated the Americans with Disabilities Act by 

subjecting an employee to discrimination on the basis of her disability and failing to provide her with 

a reasonable accommodation. The EEOC did not allege that Pipeline engaged in any discrimination 

and named Pipeline only as a successor to Tenet Healthcare, Inc. and VHS. 

 To resolve this case, EEOC, the employee, and Defendants have entered into a Consent 

Decree requiring, among other things, that: 

1. VHS pay the employee who was affected by the violations a total of $150,000 in damages; 

2. VHS is enjoined from subjecting employees to disability discrimination or failing to provide 

a reasonable accommodation; 

3. VHS is enjoined from retaliating against any employee who has made allegations of 

disability discrimination, participated in any proceeding involving discrimination under the 

ADA, or received any benefit as a result of this litigation or the Decree; and 

4. VHS will adopt and distribute a policy related to disability discrimination and reasonable 

accommodations and provide training to their employees on the policy and the requirements 

of the ADA. 

 The EEOC is a federal agency that enforces federal laws prohibiting discrimination in 

employment based on race, color, sex (including sexual harassment, pregnancy), religion, national 

origin, age, disability, genetic information, and retaliation. Further information about EEOC and 

these laws is available on EEOC’s web site at www.eeoc.gov. If you believe you have been subjected 

to unlawful discrimination or retaliation, you may contact EEOC by phone at (312) 872-9777 or by 

TTY at (312) 669-6820. The EEOC charges no fees. 

THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE

 This Notice must remain posted for four (4) years from the date below and must be altered, 

defaced, or covered by any other material. Any questions about this Notice or compliance with its 

terms may be directed to: West Suburban Medical Center Consent Decree Compliance; EEOC – 

Legal Unit; 230 S. Dearborn Street, Suite 2920; Chicago, Illinois 60604. 

_________________ ______________________________________ 

 Date Judge Robert M. Dow 

 United States District Court 

Illinois 60604.

November 19, 2021 __________________________

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