Charles Krugels July 22, 2009 City of Chicago Department of Business Affairs Seminar Handout

BY
CHARLES A. KRUGEL
HUMAN RESOURCES ATTORNEY & COUNSELOR
LABOR & EMPLOYMENT LAW ON BEHALF OF MANAGEMENT

WEDNESDAY, JULY 22, 2009, 2pm-3:30pm
CITY HALL, CHICAGO

PRESENTATION HANDOUT

1) WHAT IS HUMAN RESOURCES & WHY IT MATTERS

2) EMPLOYMENT AGREEMENTS–TO USE OR NOT TO USE?

3) HOW MUCH DOES AN EMPLOYMENT DISPUTE COST & WHAT’S YOUR
LIKELIHOOD OF GETTING INTO AN EMPLOYMENT RELATED DISPUTE?

4) WHAT’S APPROPRIATE TO ASK JOB CANDIDATES?

5) JOB CANDIDATE APPLICATION & SELECTION SUMMARY

6) EMPLOYEE SCREENING & RISK ASSESSMENT

7) INDEPENDENT CONTRACTOR VS EMPLOYEE: CLASSIFICATION ISSUES

8) OVERTIME—EXEMPT VS NONEXEMPT CLASSIFICATIONS

9) UNEMPLOYMENT COMPENSATION

10) ILLINOIS EMPLOYMENT LAWS, Some Laws Likely to be Encountered by Businesses

11) FEDERAL EMPLOYMENT LAWS, Some Laws Likely to be Encountered by Businesses

12) SAMPLE DOCUMENTATION FORM—EMPLOYEE ACTION REPORT
13) FREE RESOURCES FOR RESEARCH

14) INFORMATION ABOUT CHARLES KRUGEL, Practice & Background Summary

DISCLAIMER: THE CONTENT CONTAINED IN THIS DOCUMENT IS GENERAL & INSTRUCTIVE INFORMATION ONLY; IT’S NOT
INTENDED AS LEGAL ADVICE. THIS INFORMATION ISN’T INTENDED TO CREATE & DOESN’T CREATE AN ATTORNEY-CLIENT
RELATIONSHIP. READERS SHOULD NOT ACT UPON THIS INFORMATION WITHOUT FIRST CONSULTING WITH AN ATTORNEY.

Charles A. Krugel www.charlesakrugel.com 312-804-3851 cak1@charlesakrugel.com

What is Human Resources & Why It Matters

Human resources (HR-also referred to as human capital) is the However, time, energy & money spent upfront, or proactively,
management of employees as a capital asset. A business on HR related matters could help to reduce, & in certain
acquires & manages employees in a manner similar to the instances eliminate, the loss of money out the "back door."
acquisition & management of any other capital asset. Now Thus, HR becomes an investment in capital. Time, energy &
what exactly does this entail? money are saved & increased productivity & profits result. The
cost of employment related disputes & the savings associated
Employees are obviously human & a business resource. with proactive & preventive practices are examined later.
However, in the same way that machinery or equipment is
capital that is acquired, utilized, appreciates or depreciates in Knowing which HR practices to adopt & which HR disciplines
value, & which can be improved, sold or discarded, HR relates to focus on is crucial in resolving macro & micro HR issues.
to the management of employees in a similar fashion. Effective HR helps transform business from just a place to
Although this explanation may seem callous, when further work into a company that provides employees varied
scrutinized it is evident that HR pays as much attention to the opportunities for meaningful contributions. Meaningful
"human" half of its name as it does to the "resources" half. employee contributions lead to decreased operating costs,
increased profits & innovation. Implicit in this explanation is
HR concerns the approach & ideology a business adopts for its the fact that results are measurable via before & after analyses
culture & its employee life cycle. It’s how a business enhances & time & expense audits.
& protects its human assets, & ultimately how a business
maximizes profits. Recruiting, selecting, compensating, Labor & Employment Law Defined
motivating, maintaining & promoting employees are all part of Labor & employment law generally refers to the body of law
HR. Consequently, to some extent, all businesses with more regulating the workplace & all HR/human capital related
than one employee practice HR. Yet, an effective HR matters. However, labor law & employment law are two
philosophy has to acknowledge that because employees affect distinct categories which are often confused with one another
every facet of business, employees & HR affect profit. because they somewhat overlap.
Therefore, in order to increase profit & decrease expenses, Labor law usually refers to the body of law regulating labor
management must know how to treat employees in a way that unions & associations & their relationship with management.
enhances their value. Ultimately, effective HR helps to Such laws include the National Labor Relations Act & other
maximize profit by minimizing employment related expenses & similar federal, state & local labor laws. These laws permit
maximizing employee performance. employee organizing, electing representation & entering into
legally binding contracts with management.
In U.S. industry, modern HR theories date back to the
Industrial Revolution. Moreover, since the Industrial Generally, employment law concerns the body of law & rules
Revolution, HR has evolved along with changes in production, regulating civil rights & workplace conduct. Civil rights include
distribution, finance &, perhaps most importantly, legal & civil a workplace free from discrimination & harassment for all
rights. HR poses problems for a business when it fails to people (not just employees, it could be customers or the
understand how these changes influence macro & micro HR. public) who fit into one of the legally protected classes (e.g.,
race, gender, disability, national origin, religion, military status,
Micro & Macro HR
pregnancy, & in some instances sexual or gender orientation).
Macro HR is the strategic function of HR in a particular Conduct laws refer to the employer’s treatment of its
company. It encompasses the understanding of what HR employees. Like labor laws, these are federal, state & local
means to a business; that is, how HR fits into the laws.
organization’s structure, mission & planning. Macro HR further
incorporates policy & practice development. It’s the “big Labor & Employee Relations Defined
picture” stuff of HR. On the macro HR level, labor relations refers to the philosophy
a business adopts for dealing with labor unions, union
Micro HR is the actual execution of duties as delineated at the
organizing & employee associations. On the micro level, this
macro level. These duties include the administration of
refers to practices & rules for dealing with individual employee
policies regarding the usual core functions of HR (see above).
issues concerning unions & associations.
How Macro & Micro HR Impact the Bottom Line
Employee relations refers to the ideology (macro) a business
As stated above, a business will encounter difficulties when it adopts for dealing with harassment & discrimination & other
fails to account for changes to macro & micro HR practices & employee issues. This is generally unrelated to labor unions or
changes to our labor & employment laws. Such difficulties employee associations. This may include communication,
include an unsafe workplace, attendance issues, employee discipline, recognition & payroll policies. On the micro level, it
conflict, union organizing & litigation. Simply stated, when a generally refers to how laws & rules are applied to individual or
business encounters HR related problems, money is lost. groups of employees.
Businesses have money coming in through the "front door" via
revenue, venture capital, grants, investors, etc. However,
much of this money can exit through the "back door" because
of poor HR practices. For instance, time & money is lost when
a business realizes that it hired the wrong employee & may
now have to discharge that employee. Consequently, that
business will have to spend money & time finding & training a
new employee & may even have to defend its treatment &
discharge of the former employee. Recognizing & efficiently
resolving these problems often costs a great deal of time,
energy & money.
Charles Krugel’s Seminar Handout, 7/22/09, Page 2/21
© 2006-2009 Charles A. Krugel; All Rights Reserved

Employment Agreements–to Use or Not to Use?

These agreements are used to protect employers Obviously, the most extreme action an employer can
from a variety of problems: legally take is to sue the ex-employee for violating the
• To discourage some sort of employee conduct agreement. But, a lawsuit costs a lot of time &
(e.g., noncompete or nonsolicitation), or to money, even if damages, costs & expenses can be
identify conditions & terms of employment; recovered from the employee.
• During pre-hire to define wages, hours, benefits, A lawsuit or some other sort of complaint filed by the
confidentiality, protection of business secrets & ex-employee might be easier to deal with. As long as
other similar information; the terms of the agreement’s confidentiality,
• Upon separation of employment as a sort of nondisclosure & other prohibitions are legally
insurance to obtain a waiver of any legal or compliant, no court or other tribunal should
statutory claims, provide unearned severance or adjudicate a lawsuit or complaint against the
separation benefits; & employer, & costs, expenses & damages should be
• During employment for promotions, demotions, awarded to the employer.
wage deductions, garnishments, & waiver of any
legal or statutory rights. Clients typically ask whether entering into an
employment agreement creates a legal precedent
When considering whether to use such an within their company or a feeling or belief of
agreement, a business should determine the entitlement to such a benefit among employees. In
following: short, it’s not likely that the company will be legally
• What employee (or ex-employee) conduct is obligated to offer the same benefit. However, if
being encouraged or discouraged? others learn about such agreements, there’s a
greater degree of possibility that complications like a
• What’s being protected? What’s the value of the sense of entitlement will result. So, when deciding
protected information or items?
whether to use employment agreements, a business
• What will it cost to enforce the agreement in case should consider the impact on employee morale &
of violation? What are the actual & foreseeable the legal ramifications of using such an agreement.
damages due to violation?
• How much is lost vs. saved or gained by using The concerns regarding employee morale & feelings
these agreements? It’s all about the money. of entitlement can be combated by using these
• Should the language & format of the agreement agreements infrequently or in extreme circumstances
reflect the business’ employment policies in tone (e.g., in order to protect company confidentiality,
& language, or is it a completely isolated capital, etc.), & making it clear to employees that they
document? are at-will employees (if applicable).

No hard & fast rules exist for when & how to In other words, it’s relatively easy in an article like this
incorporate employment agreements, & for the most to state in a generic & sterile manner what should or
part, they’re not legally required unless certain shouldn’t be done. It’s a completely different matter
circumstances exist such as to waive any legal or to actually draft & execute an agreement in a way
statutory claims, or to legally bind the other party to that sufficiently communicates that this is an isolated
some sort of obligation. & unique circumstance, & a serious & binding
agreement with provisions that must be honored.
Special attention must be paid to every aspect of
wording, organization/layout & legal compliance. In short, how employment agreements are
Conciseness, plain language & thoroughness cannot implemented is crucial. Issues with execution are
be stressed enough. what lead to misunderstandings & disputes. But,
many of these issues are avoidable & resolvable via
However, all agreements should permit the employer a professionally drafted & executed agreements &
to recover damages, costs & expenses from the the advice of competent legal counsel.
employee or other party (assuming law permits such
recovery). This won’t absolutely prevent a breach
from occurring, but it’s a great preventive measure.

Enforceability of agreements is often an issue
because if a breach occurs, the employer still needs
to take enforcement action. This does not
necessarily mean that the employer has to sue. The
employer can issue some type of warning (letter,
phone call, etc.), or the employer can contact the
opposing party. The latter action poses its own risks
due to ethical concerns, antitrust, defamation, libel &
slander concerns.

How Much Money Does an Employment Dispute Cost &
What’s Your Likelihood of Getting Into an Employment Related Dispute or Being Sued?
The Cost
One approach to determining cost is past experience. I’ve still cost money to handle & resolve. From “Working Up a
settled employment cases at the administrative level for as Suit” by Barbara Bowers, Best’s Review, Jan. 2005, Vol. 105,
little as $1,000. However, past performance is neither a Issue 9.
reliable predictor nor a guarantee of future performance.
According to the EEOC, they filed:
Here’s another way to compute the cost of a dispute: If a 403 in FY 2006 (FY 10/1–9/30),
complaint is filed with an administrative agency such as the 362 in FY 2007; & oddly enough declined to
Equal Employment Opportunity Commission (EEOC), a 325 in FY 2008, the lowest in 12 years.
business should expect to pay a minimum of 5 hours for
The monetary benefits paid over all of these suits averaged
attorney’s fees to just negotiate a quick settlement. Thus, if
$110k in 2006, $151k in 2007 & skyrocketed to $315k in
attorney’s fees are $250/hour, miscellaneous costs are
2008. From www.eeoc.gov.
$50, & the settlement reached is $1,000, that’s $2,300.
This doesn’t even include the cost of employees spending Regarding money paid on all complaints, not including
time away from work to deal with this matter, & any other lawsuits, from fiscal years 2000-2005 an average of $251.8
transportation, gas or lost sales, profits, etc. If the case million was paid by businesses. From www.eeoc.gov.
isn’t quickly settled or if it proceeds to court, then we’re
looking at additional expense. Interestingly, the number of actual charges filed with
the EEOC by employees has increased. From FY
Another cost is the employee’s damages. Damages may
include back pay & benefits, front pay, punitive or
1997-FY 2001, an annual average of 79,690 charges
exemplary damages, reinstatement or promotion. were filed. In FY 2002, the most charges in the last
Furthermore, a court or agency may order training (e.g., 11 FYs were filed—84,442. The number dropped to
diversity & harassment), affirmative action & monitoring. 81,293 in FY 2003; 79,432 in 2004; 75,428 in 2005; &
Those are additional & substantial costs that the business 75,768 in 2006. But, in FY 2007, the number of
may bear. charges filed increased to 82,792, & in FY 2008
According to Jury Verdict Research (JVR), which compiles
jumped to 95,402. From http://www.eeoc.gov.
samples of employment discrimination verdicts for analysis, The above numbers just relate to the EEOC. This
the median compensatory award for employment related leaves out the courts, the Illinois Department of
cases, among all economic sectors:
Rose from $200k in 2006 to $252k in 2007;
Human Rights, the Cook County Commission on
Overall from 2001-2007 the median award rose Human Rights, the federal & state labor departments,
from $147.5k to $252k or 70%. labor boards, Homeland Security, etc. There’s a lot
From 2001-2007, the median verdict in federal of money at stake here.
court discrimination cases was $175k, but it was
$250k for state court verdicts; As I said before, it’s much cheaper to prevent these
Among settlement of cases, 23 % resulted in problems from arising via proactive or preventive
payments of $100,000 to $250,000; about 18% human resources. For example, according to JVR:
were over $250,000; & It costs $5,000 to train 200 employees at $25
These above award and settlement amounts are each on employment issues such as
exclusive of legal fees—both claimants and harassment & discrimination.
defense fees. Cumulative legal fees sometimes If that same company is sued, the cost to
exceed the cost of liability. litigate the case is approximately $155,000, &
According to insurance industry research:
the cost to settle is about $85,000.
The general cost to settle a “frivolous employment Yet, the cost to litigate or settle an individual
case is $30,000-$40,000 (per a March 2005 case, when no training occurs, is $960,750 to
statement from a Senior Vice President of London litigate & $304,000 to settle.
American General Agency; & From “Risk Management–Why Train?” 2006,www.emtrain.com,
550 employment related lawsuits are filed every citing JVR’s “Employment Practice Liability: Jury Award Trends &
Statistics, 2005 Edition.
day (per a March 2005 statement from a Vice
President of the National Union Fire Insurance In short, it pays for almost any business of any size,
Company). From: “Heads Up! Employees at Large,” in to have a basic understanding of human resources &
www.insurancejournal.com.
employment law, & to have access to a great labor &
employment attorney.
The Likelihood of Getting Into a Dispute

Some statistics compiled by government & private industry
might help to determine the probability of an employment
related complaint or suit being filed, in addition to the cost
to settle or litigate these complaints.
According to a 2004 Chubb Insurance (www.chubb.com)
survey, during the previous few years, 1 in 4 or 25% of
privately held companies have been sued by an employee
or former employee. However, it’s estimated that 75% of
these claims are groundless. Nevertheless, these claims

What’s Appropriate to Ask Job Candidates?

Although there are only a few explicitly illegal questions that Regarding military record, you cannot ask about discharge.
an employer should never ask a job applicant, there are You can ask about the applicant’s education, training & work
many other questions which might lead to the inference that experience while in the military.
the employer is discriminating a member of a protected class.
One way to help minimize liability for discrimination is to ask Relative to languages spoken, if the job requires language
all applicants all of the same questions. fluency, other than English, then you can ask if the applicant
has that ability. However, you shouldn’t ask what the
Additionally, it’s crucial to focus on questions related to the applicant’s native language is. This could lead to an
essential job functions. Or, put another way, are the inference of national origin or race discrimination.
questions asked intended to solicit information connected to
the applicant’s ability & willingness to perform the essential It used to be asked of applicants what clubs, organizations,
job functions, or are they more indicative of illegal bias? In or societies they belonged to. Now, due to their association
almost all cases, it’s not an essential job function to be of a with excluding members of protected classes, these
certain race, age, sex, sexual orientation, etc. Exceptions questions are unadvisable. You can ask about membership
are extremely limited. or associations only if they directly relate to the applicant’s
ability to perform the essential job functions. E.g., “We
Don’t ask questions to determine if the applicant has children expect you to become involved with local chambers of
or dependents, or plans to start a family. Such questions commerce, because this is how we develop new business &
include asking about the number of children, having a alliances. Do you have problem with this?”
babysitter or even if the applicant has a car (unless, the job
requires that the applicant has their own transportation). If Relative to time off from work, work related injuries or
the candidate indicates that they’re pregnant, then worker’s compensation, you should never ask if the applicant
congratulate them, but don’t relate their pregnancy to the job has ever filed for worker’s compensation, unemployment
unless they indicate a need for some sort of accommodation. compensation or if they have ever sued or filed a complaint
against a prior employer. Also, you should never ask if the
Questions to determine an applicant’s reliability are okay. applicant had any prior work related injuries. Again, you can
Such questions include asking what hours & days the person ask if there are specific days or times that the applicant can’t
can work, specific days or times they can’t work, or if they work, or if the applicant can do the essential job functions.
have outside responsibilities that will interfere with work.
You can ask behavior oriented questions such as how the
Relative to an applicant’s national origin, don’t ask questions applicant handled prior workplace disruptions or disputes, or
to determine where the candidate is from. It’s okay to ask if how they would handle job related issues or matters that are
the applicant is legally eligible to work in the U.S., or if they related to the position.
have ever worked under another name.
Asking about religious & ideological beliefs, associations or
With respect to arrest & conviction records, you can’t ask if affiliations is usually indicative of illegal bias. They rarely, if
the applicant has ever been arrested. You can ask if they ever, relate to the essential job duties & will only serve as an
have ever been convicted of a crime. If they’ve been invitation to lawsuits. An exception is if your organization or
convicted, then you could also ask what, when & how the business is a religious organization.
case was resolved. Essentially, you should only be
concerned with a criminal conviction if such information Don’t ask about gender or sexuality, including bisexuality,
relates to essential functions; e.g., handling money or being homosexuality or trasngenderism. Don’t ask about titles
around kids. Moreover, the date of conviction may be such as Mr., Ms., Mrs. or Miss.
relevant depending on the magnitude of the crime. For Previous addresses (residential) have traditionally been
example, 5 years after conviction or completion of the asked on job applications & interviews. Such information is
sentence or probation could be a good cut off date for lesser rarely related to job duties, skills, abilities or knowledge. So,
felonies. Also, acquire an applicant’s written don’t make this inquiry. If such information is truly relevant,
waiver/permission to do a criminal background check. then you can get this by doing a credit or background check.
You can’t ask if a candidate has any physical or mental Also, asking someone when they graduated college or high
disabilities. Also, don’t ask if the applicant has an alcohol or school may be indicative of age bias, so don’t ask this. You
drug problem, or if they take any medications. Exceptions could ask what kind of education or degrees they have.
include if the applicant explicitly & without your solicitation
discloses any disability, impairment, drug or medication You can ask an applicant’s date of birth to determine
usage. If this is the case, you can ask if they can work the employment eligibility. Use a disclaimer or indicate that the
hours & days you specify, or if the applicant has nonwork applicant is being asked only to determine eligibility.
related responsibilities which would interfere with their ability
to perform the essential job functions. Moreover, you can
Some of the information contained in this page was adapted from the
ask if the applicant can perform the essential job functions following articles: Society of Human Resource Management
with or without an accommodation. Whitepaper-Guidelines on Interview & Employment Application
Questions” by Nail & Scharinger, 1998, 1999, 2002; Society of
Relative to credit record & financial history, you cannot ask if
Human Resource Management Whitepaper: “ADA Job Interview
the applicant owns or rents a home, if they’ve ever had Checklist for Supervisors,” by Pritchard, 1992, 1999, 2002; & “333
wages garnished or if they’ve ever declared bankruptcy. You Interviewing Questions,” by Borgman Associates, 1993.
can disclose that you’ll be conducting a pre or post job offer
credit check in compliance with the Fair Credit Reporting Act
& the Consumer Credit Reporting Reform Act (obtain
candidate’s written permission to check).


Job Candidate Application & Selection
Summary

Focus on the essential functions of the job. Describe a situation where your
Essential job functions usually defined by a valid employer asked you to do something
job description. which you believe may have been
unethical or unprofitable for the
For all candidates: business? How did you handle this?
Ask the same questions, What was the outcome?
Use the same background checking
processes, use the same tests; & Background Checking—Compliance with federal
Score/assess the same way; i.e., don’t laws like the Fair Credit Reporting Act, Consumer
adjust scoring/assessment system unless Credit Protection Act & state law like the Illinois
for a valid &/or legal purpose. Uniform Conviction Information Act is contingent
upon:
Don’t discriminate in the hiring process on the disclosure of the background check;
basis of any protected class (see below), unless: disclosure of the reason for
mandated pursuant to a legally binding background check;
order or agreement, or procurement of candidate or
you’re doing so based on a “bona fide employee’s written release(s)—could
occupational qualification.” be more than 1 release depending on
the checks conducted.
Can ask if candidate can perform the essential job Also:
functions with or without a reasonable subsequent to the selection process, if
accommodation. a candidate or employee is rejected as
Reasonableness is generally a result of the check, then provide that
contingent upon why needed, cost & person with the relevant part of the
feasibility. report & summary of rights/ recourse
options.
Don’t ask questions intended to elicit, or which
unintentionally elicit, information regarding: Per the Illinois Criminal Identification Act you can’t
race ask job applicants to disclose criminal convictions
gender which have been expunged or sealed, & you can’t
religious beliefs ask if applicant has any expunged or sealed
age convictions & records.
sexual orientation
disability Employment Testing:
military status Make sure that the test is valid, reliable
socioeconomic status-own home, rent & used for the purpose(s) intended.
home, how will pay for home,
education, etc.
national origin.

Currently, it’s popular to ask behavioral questions.
These questions might be useful as they’re
generally nondiscriminatory, & they elicit
performance & conduct related information.
Examples of such questions include:
Describe a situation in which you &
another coworker conflicted. What
happened? How did you deal with the
situation? How was the situation
resolved?


Employee Screening & Risk Assessment

Co-Authored by Tony Ramos & Charles Krugel

Recent headlines of workplace violence, violence by home method, check all candidates & employees, conduct the
service personnel, as well as convicted rapists working as search in a good faith & reasonable manner, & use the
private security officers or childcare providers, have raised results of those checks in a good faith & reasonable fashion.
serious questions regarding employee screening programs. As with all human resources related matters, in order to
minimize expense & legal exposure, focus on prevention &
What is negligent hiring? proaction--research your screener & work with them to best
Should all companies be expected to have a screening determine what you need & why you need it.
policy?
Does every employee need to be screened? Vendor Selection - Tony Ramos
What is considered an acceptable screening program? Selecting the wrong screening vendor can be equal to or
How much should a company expect to pay for more devastating than hiring the wrong employee. The
screening? wrong vendor can provide you with nothing more than a false
What can it cost a company should they chose not to sense of security.
have a screening program?
Are all screening companies alike? Select a vendor who has the knowledge, experience & can
clearly explain your screening options & their limitations.
According to attorney Charles Krugel: Typical choices include state, county court, national criminal
Negligent hiring & negligent retention lawsuits are increasing, databases & fingerprint searches. There are also choices of
& so are employer expense & liability as a result of these supplemental screening options which include driving record,
suits. Underlying the idea of negligent hiring & retention is an credit reports, workers compensation, employment history,
employer's legal responsibility to provide employees, educational history & civil records as well. Your vendor can
customers & the public a reasonably safe environment, & the assist you in developing the right plan to match your needs.
liability imputed to employers when they fail to exercise Basic Program
reasonable care in providing such an environment. It's when Vendor Selection
this failure occurs that as an employer, your business, could o Select a vendor who can demonstrate a national
be held liable for negligent hiring or retention. hit rate of at least 10%. Hit rate is the most
Consequently, from a cost containment & legal liability effective way to determine the quality of the
perspective, it's increasingly crucial that businesses conduct service. In short, for every 100 applicants
criminal background checks, conduct such checks in a screened, the vendor should be finding at least 10
competent manner & take reasonable action as a result of with a criminal record. Don’t be surprised if a
these inquiries. This means that if an employer undertakes vendor is hesitant or actually refuses to provide
criminal background checking, in order to avoid legal liability, this information. Many operate with only a 6% or
it should carefully choose who does the screening as well as less hit-rate.
what’s searched. Social Security Trace
o This will help validate the number & provide up to
Although, Illinois doesn't require many businesses to screen ten-years of past residential history & names or
job candidates (most education & social service aliases used.
organizations are required to screen candidates), & the County-court Record Search
Illinois Human Rights Act mandates that an employer cannot o Counties to be searched should be selected
use a candidate's "arrest record" as the basis for denial of based on the results of the trace & never from the
employment (narrow exceptions exist), the possible liability job application. This will also provide you with the
resulting from a business' failure to screen can cripple that most accurate & current information available.
business. According to a 2001 report by the Society of National Criminal Database Search
Human Resources Management & American Background o For a more comprehensive program, include a
Information Services, Inc., the average settlement for national criminal database search. Important
negligent hiring lawsuits exceeds $1.6 million. note, database findings must be verified by court
records before acting upon them. Also, databases
Obviously, much of the burden falls on employers, with the searches should only be used to supplement an
guidance of competent legal counsel & screening actual court record search & not in place of.
professionals, to determine what constitutes a competent FCRA (Fair Credit Reporting Act) Compliant
background search. Generally, such a search is based upon o Ensure your vendor is fully FCRA compliant, this
the essential requirements of the position & the industry's will provide you with additional protective
particular circumstances. immunity against some civil lawsuits.
Usually, courts don't examine why screening is done. The Cost
courts look at why the essential duties of the job, & the o While there are many factors such as volume &
particulars of the business' industry, necessitate the need to types of screening options selected which
screen out convicted criminals, & which types of crimes determine the actual cost, one can expect to pay
prevent a candidate from being hired. Therefore, just $20 to $35 per person.
knowing that a job candidate has been convicted of a crime Co-Author: Tony Ramos, tramos@intergasecurity.org, has also
may not be enough to insulate your business from liability. authored “The Guide to Background Checks” which he developed for
You’ll probably need to know the exact nature of the the Illinois Association of Chiefs of Police & is available for download
conviction & connect it to the job. from his web-site at www.integrasecuirty.org

In short, as a business, if you undertake criminal record
checking, then choose a competent screener & screening


Independent Contractor vs. Employee: Summary
of Classification Issues
Advantage of the independent contractor classification: secondary schools), outside sales employees,
Avoid federal & state withholding taxes. & certain skilled computer professionals;
Disadvantage:
Employees of certain seasonal amusement or
If improperly classified (intent is irrelevant),
recreational establishments;
then penalty may include payment of taxes by
Employees of certain small newspapers &
employer & 5%−25% penalty for each month.
switchboard operators of small telephone
How to Distinguish Between the Two: companies;
Degree of control & independence is the key. Employees in newspaper delivery; &
Independent contractors have a great deal of Casual babysitters & persons employed as
control over their working conditions, companions to the elderly or infirm.
environment, & freedom to work for anyone.
The following are examples of workers exempt
Such control might include control over
from overtime pay requirements:
work schedule, when paid, work for
other businesses, location of work, Certain commissioned employees of retail or
able to maintain separate/distinct service establishments;
identity. Auto, truck, trailer, farm implement, boat, or
Commission pay might not matter. aircraft salespersons, clerks & mechanics
Use own work methods; not trained by employed by non-manufacturing
the principal; outside principal’s scope establishments primarily engaged in selling
of expertise. these items to ultimate purchasers
Use own tools, materials, etc. (consumers, businesses);
Closed ended contract/agreement with Railroad & air line employees, taxi drivers,
a start & finish date. some employees of motor carriers, & local
Employees have little control over the above- delivery employees paid on approved trip rate
mentioned factors. plans;
Employees are subject to using the Announcers, news editors, & chief engineers
employer’s materials, tools, processes, of certain non-metropolitan broadcasting
property, etc. stations;
Employees generally work within Domestic service workers who reside in their
scope of principal’s core services. employers' residences; &
Employees of motion picture theaters.
See the following for additional information:
www.irs.gov. Certain employees may be partially exempt from
the overtime pay requirements. These include:
Overtime—Exempt vs. Nonexempt Classifications
Employees engaged in certain operations on
Overtime at a minimum of 11/2 times the regular rate agricultural commodities & employees of
of pay is required after 40 hours of work in a certain bulk petroleum distributors;
workweek. Employees of hospitals & residential care
establishments that have agreements with the
Don’t arbitrarily classify. This will probably lead to an employees that they will work 14-day periods
illegal classification. in lieu of 7-day workweeks (if the employees
Most businesses are covered by the Fair Labor are paid overtime premium pay within the
Standards Act. This is the federal law governing requirements of the Act for all hours worked
minimum wage & overtime. over eight in a day or 80 in the 14-day work
period, whichever is the greater number of
Exclusions exists for businesses earning less than overtime hours); &
$500k in annual revenue & not engaged in interstate Employees who lack a high school diploma, or
commerce or hospitals; institutions primarily engaged who have not completed the eighth grade, who
in the care of the sick, aged, mentally ill, or disabled spend part of their workweeks in remedial
who reside on the premises; schools for children who reading or training in other basic skills that are
are mentally, or physically disabled or gifted; not job-specific. Employers may require such
preschools, elementary, & secondary schools & employees to engage in these activities up to
institutions of higher education; & federal, state, & local 10 hours in a workweek. Employers must pay
government agencies. normal wages for the hours spent in such
training but need not pay overtime premium
The following are examples of employees exempt from
pay for training hours.
both the minimum wage & overtime pay requirements:
For additional information see: www.dol.gov.
Executive, administrative, & professional
employees (including teachers & academic
administrative personnel in elementary &

The Costs of Unemployment Compensation (UC)
Claims
Co-Authored by David Prosnitz & Charles Krugel

Generally, a company’s unemployment tax rate is misconduct standard, vague reasons for firing an
experience rated: it goes up or down over time employee often lead to unemployment benefits. More
depending on a company’s history with awarded specifically, a former employee will be disqualified from
unemployment claims. receiving unemployment benefits if they were
terminated for misconduct or they quit for reasons not
In Illinois, for example, rates vary between 1.0% & attributable to the employer.
8.2%. The first $12,000 of each employee’s wages will
be taxed in 2008. So, a million dollar taxable payroll While many factors are beyond the employer’s control,
can have unemployment taxes between $10,000 & the main reason for a company’s unemployment tax
$82,000. Obviously, lower tax rates make a difference rate increase or decrease is the eligibility or ineligibility
to the bottom line. of former employees who file for UC. If fewer people
collect against a company, over time, the company will
The actual cost of a claim may vary, since claimants have a lower tax rate. If more people collect against a
may collect just 2 weeks or 26. The average claim company, the rate will go higher. If an employer
costs an employer $4,200 but claims can cost a successfully contests its unemployment claims, it can
company in excess of $10,000. gain control of its unemployment tax rate.
Each claim can affect 3 years of unemployment tax
Terminating for Misconduct (Including Conduct,
rates since state formulas used to assign rates
Excessive Absenteeism & Tardiness)
ordinarily use a 3 year moving period to assign a tax
rate. This is one reason why employers don’t realize Employers should have a UC cost control program & it
the expense involved in a single claim. The expense is should consist of three parts.
spread over a 3 or 4 year period.
First, the employer should discipline & terminate
Smaller employers are hit harder by single claims than employees in light of the misconduct standard used by
larger ones, though the different impact of a claim on a many UC agencies. Basically, misconduct is an
tax rate does not change the actual cost to the intentional or willful act of wrongdoing that does harm
employer significantly. The average cost, big firm or or potential harm to the employer & that violates a
small, of an unemployment claim is $4,200. known or reasonable rule. Additionally, it’s something
Employers can contest the cost of these claims by for which the person had been warned, or the action is
fighting unwarranted applications for benefits. of such magnitude that no warning is necessary (e.g.,
Employees terminated for misconduct or employees theft or violence).
who quit for reasons not attributable to the employer Second, the employer should warn appropriately
are legally not entitled to unemployment benefits. because prior warnings help prove the willful nature of
If employers do not fight unemployment claims, they the last wrongdoing. The UC administration ordinarily
are meekly acquiescing to their costs. This permits wants one warning in the year prior to discharge.
claimants who behaved badly at work to collect a Generally, it's best if the employer has a progressive
reward for their bad behavior & it insures that the warning system though, depending on the nature of an
employer pays an unreasonable tax expense. offense, the employer may warn, suspend or terminate
at any time. The life of a disciplinary action, from the
Eligibility for UC standpoint of the UC system, is a year. So, if after a
suspension, the employee has no related incidents for
Because UC is a government administered a year, on the next occurrence, progressive discipline
bureaucracy, like much of government, it’s not starts over at the warning level.
administered in a cost effective, logical or exacting
manner. Many factors play a role as to whether & how It helps if the employer behaves as a reasonable
an employee will be eligible or ineligible for UC. person might. That is, employees should be
terminated only when there is proof of wrongdoing.
Usually, if an employee is fired due to intentional The infraction should be serious in the sense that there
wrongdoing, refuses reasonable employment & then was harm or potential harm to the employer, the
becomes separated, quits for reasons not attributable infraction should violate a known or reasonable rule, &
to the employer, or is not able & available for work, the employee should have had an appropriate warning.
they’re not eligible for UC. If the employee is A reasonable person will discuss the wrongdoing with
separated from employment through no fault of their the employee. This is a check on the employer’s
own, whether for lay off, furlough, reduced hours, or reasonableness; & should the employee admit to
there appears to be mixed or uncertain causes for wrongdoing, this also is good evidence for the
separation (e.g., poor performance, undocumented employer.
problems, constructive discharge), then they’ll be
eligible for UC. Since an employee must do something Third, employers should document all infractions,
discernibly wrong to be denied benefits under the especially ones that lead to termination. This shows


that the employer fired the employee for what occurred isn’t proper, unless it’s to document what the
at that time, since the form should have been employee or a witness indicated & if it’s
completed when the wrongdoing happened. relevant to the incident being documented
Recording disciplinary actions in writing may also help
the employer remember details they would otherwise When to Contest or Not Contest an UC Claim
forget. & the proof of a wrongdoing is often in the
details. Documentation is further discussed in the next All unwarranted UC claims should be contested, & they
section. should be contested as soon as the claim is received
(not after it advances to the appellate levels) & within
Also, remember that if an employer discharges an the mandated time period. It’s always cheaper &
employee within the first 30 days of employment, easier to contest a claim at the lowest administrative
Illinois doesn’t find that business chargeable for UC. level of the claims process.
However, employers need to understand that problems When or If to Appeal a Claim
such as employee incompetence or performance
issues do not usually constitute misconduct. Whenever it’s either cost effective, the employer didn’t
Moreover, personality issues or failure to fit into the properly represent itself or wasn’t properly represented
workplace aren't sufficient reasons to negate the at the lower level of claims processing.
awarding of UC. Attitude, personality, incompetence &
performance issues have to be tied to some sort of Following UC Guidelines in Making Terminations
willful misconduct by the employee in order for the Relates to Labor & Employment Laws
employee to be denied UC.
The fact is that in almost all circumstances employers
The What, When, Why & How of Documentation can’t take any employment action on the basis of race,
sex, national origin, ethnicity, religion, socio economic
Documentation is a key to winning UC claims because status, military status, disability, age (40 & older),
government bureaucrats are looking for the most marital status, family status, union activity, & in an
efficient & professional way to decide claims. The increasing number of jurisdictions—sexual orientation,
quality & quantity of information available makes the & any other legally protected class or category. These
government official’s job easier. If an employer makes prohibitions equally apply to unemployment
the bureaucrat’s job easier, the employer’s effort will be compensation.
rewarded. Here’s what the UC administration typically
looks for: However, if an employer utilizes the concepts of equal
employment opportunity & the misconduct standard, &
• Easy to read & understand creates a workplace free from legally prohibited
• Consistent—using the same forms, filled out in harassment & discrimination, it’s much easier to
the same way, consistent language maintain a legally compliant workplace. Moreover, the
employer will be able to minimize their unemployment
• Details: Date, time of day, names/signatures, compensation expenses.
job titles
• Indicate the level of discipline; i.e., 1st warning, Employers need to remember that when documenting
incidents or when reporting to a state’s UC agency
final warning, probation, etc.
they should not make any references to the protected
• Quotations or paraphrasing/summarizing of classes unless for the purposes of quoting or
employee statements are useful summarizing what another employee said & for
• Indicating whether the employee signed or clarifying the record. An employer’s failure to do so
received any documentation; or if employee may not just result in the awarding of unemployment
refused to sign or receive the same compensation, but may also result in an agency
complaint or a lawsuit.
• Employment policies/practices that are easy to
read & understand Just remember to act without regard to the protected
Documentation should be created classes, train the entire workforce & follow company
contemporaneously with or ASAP after employment policies.
the event to be documented occurs;
doing so increases the credibility of the David Prosnitz is the founder & president of
documentation Personnel Planners, www.unemployment
• Impressions are okay; personal judgments claims.com, a Chicago based unemployment
about the employee aren’t compensation cost control company that
Indicating that the employee is lying, services more than 800 businesses.
nervous, upset, angry is okay
Calling the employee a “scumbag,”
“piece of *&$@” or any other profanity
or name isn’t okay
• Any of the documenter’s personal opinions or
observations referencing any protected class

ILLINOIS LABOR & EMPLOYMENT LAWS

Some Laws Likely to Be Encountered by Businesses

Act/Law Coverage Basic Requirements Damages/Penalties

Attorneys Fees in Must pay all wages owed to an Employer liable for reasonable
All employers
Wage Action Act employee once separated. attorney’s fees & costs.

Fines up to $100 for 1st violation; up
to $500 for 2nd violation w/in 1 year;
Chicago Clean Smoking banned in enclosed
up to $2500 for each additional
Indoor Air All employers workplaces. Post appropriate
violation w/in 1-year & a 60-day
Ordinance signs/notices.
suspension or revocation of any
permit or license.

Can’t discriminate on basis of
race, color, sex, age, religion,
disability, national origin,
Fine of $100 to $500 per violation.
Chicago Human ancestry, sexual orientation,
All employers Each day a violation continues is a
Rights Ordinance marital status, parental status,
separate offense.
military service, source of income
or social status. There are
narrowly construed exceptions.

Pertains to children under 16;
Each violation is a Class A
children 14 & 15 years old can
misdemeanor. Each day out of
work, but employer must obtain
Child Labor Law All employers compliance is a separate violation.
certification. Limits work to 3
Violations are subject to a fine up to
hours on a school day or 18
$5k for each violation.
hours in a school week.

Can’t discriminate on basis of
race, color, sex, age, religion, Actual damages, back pay,
disability, national origin, attorney’s fees & costs, fine of $100
Cook County
ancestry, sexual orientation, to $500 per violation. Each day a
Human Rights All employers
marital status, parental status, violation continues is a separate
Ordinance
military service, source of income offense. Remedial action; e.g.,
or social status. There are hiring, reinstatement, promotion.
narrowly construed exceptions.

Expunged or sealed criminal
records may not be considered
by any private or public entity in
employment matters, certification
All employers or licensing matters. Applications
(except many law for employment must contain Not specified. Probably actual
Criminal
enforcement or specific language stating damages & equitable relief. Case
Identification Act
prosecutorial applicant isn’t obligated to decisions may provide explanation.
agencies) disclose sealed or expunged
records of conviction or arrest.
Employers can’t ask if an
applicant has had records
expunged or sealed.
Employer that knowingly fails to
comply is subject to a fine of $15
per employee not reported within 21
Directory of New Must report identifying
days after being notified by IDES.
Hires (part of the information on all new employees
All employers An employer conspiring with the
Unemployment within 20 days of first workday to
new employee to avoid the law is
Insurance Act) Illinois Directory of New Hires.
guilty of a class B misdemeanor &
eligible for a fine no greater than
$500 per unreported employee.


Employer must publish a notice
that drugs (e.g., controlled
Employers of 25 or substances) are prohibited in the Suspension of payment, termination
Drug Free more & with state of workplace, that actions will be or debarment, ineligibility for any
Workplace Act IL contracts or grants taken for policy violations, & that state contract/grant for at least 1
of $5k or more employees must notify employer year, but not more than 5 years.
within 5 days of any criminal drug
conviction.
Up to $1,500 civil penalty per
All construction, violation; up to $2,500/violation for
Employee trucking, Can’t misclassify “employees” as repeat violations; debarment from
Classification Act landscaping, building “independent contractors.” state contracts. Individuals have a
& related trades private right of action for $
damages, including fees & costs.

Employer providing a job
Employment reference to a prospective None specified (but perhaps an
Record All employers employer will have civil immunity employer can be held liable for libel,
Disclosure Act if it provides truthful & only job slander or defamation?).
performance information.

Pay equal wages for equal work.
Employers of 6 or
Exceptions permissible due to Fine of $25 to $100 for each
Equal Wage Act more engaged in any
differences in skills, abilities, violation.
manufacturing
training, education, tenure, etc.

Illinois Insurance Upon employee separation,
Act--Continuation employer must provide
Law, Spousal COVERED employee who has
All employers with
Continuation Law, been enrolled in the plan for at
group health None specified although payment of
& Dependent least 3 months, prior to
insurance & HMO premiums is possible.
Child separation, the option to continue
contracts in Illinois
Continuation Law hospital, surgical & major
(state equivalent medical coverage for 9 months
of fed. COBRA) for self & dependants.

Employers of 15 or Damages include: Cease & desist
Can’t discriminate against
more working during order, actual damages, emotional
employees on basis of race,
20 or more weeks in distress, hiring, reinstatement,
color, national origin, sex, age,
IL Human Rights the calendar year. promotion, back pay & benefits;
marital status, military status,
Act But, if disability or attorney’s fees & costs; compliance
religion, arrest record or
sexual harassment reports; posting of notices; penalty
handicap. Maintain records for 1
alleged, then Act payments to the state; loss of state
year; indefinitely for complaints.
covers all employers contracts for up to 3 years.

Employers are required to
Illinois Income withhold $100/per day with no limitation.
Withholding for All employers pay/salary/compensation Each day in violation is a distinct
Support Act pursuant to court ordered child violation.
support or spousal maintenance.



If conducting criminal
Up to $1k for willful violation, plus
background checks for
IL Uniform All employers actual & general compensatory
employment purposes, must
Conviction conducting criminal damages, attorney’s fees & costs.
obtain applicant’s signature for
Information Act background checks Criminal penalties in certain
release & maintain on file for at
circumstances.
least 2 years.

Employer’s refusal may be grounds
for court action to recover entire
amount of the debt from the
IL Wage Employer obligated to honor a
All private employers employer. Employer can’t fire or
Assignment Act valid wage assignment.
suspend employee due to wage
demands; may be a Class A
misdemeanor.

Employer must pay all wages at
least semi-monthly & within 13 Employer liable for penalty if the IL
days of when earned. Must pay Dept. of Labor determines wages
wages & unused vacation time owed, & employer doesn’t pay.
IL Wage Payment
All employers upon end of employment, but not Penalties are 1% per calendar day
& Collection Act
later than next payday. up to double the amount of the
Exclusions for certain exempt award; may be found guilty of a
employees & per Class C misdemeanor.
contract/agreement.

Employer must allow time off for
jury duty. Can’t retaliate for time
off. FLSA exempt employees
Employer may be charged with
Jury Act (Right to must be paid (offset for nominal
contempt of court & any damages
Time Off for Jury All employers jury duty pay permitted).
for lost wages & benefits. Also, if
Duty) Employee must provide employer
employee fired then reinstatement.
a copy of the summons within 10
days of the date of issuance of
the summons to the employee.

Employer must pay for
Medical prescreening or post offer Violations are a petty offense &
Examination of All employers medical exam, if exam is a carry a fine of up to $100 for each
Employees Act condition of hiring or offense.
employment.

Workers 18 & older; Payment of back wages, legal
Minimum Wage 4 or more costs, attorneys’ fees. Other
Starting 7/1/09 $8.00/hour; &
Law employees, penalties including punitive
7/1/10 $8.25/hour.
(Illinois) excluding family damages (up to 20% of back
members wages) may apply.

Employer must provide non-
executive & non-professional
employees 24 consecutive hours
off in every calendar week.
Most employers Exceptions include part-time
Each violation incurs potential fine
One Day Rest in (exclusions for employee working less than 20
of $25 to $100. Also may be found
Seven Act emergency, safety & hours, emergencies, security
guilty of a petty offense.
security workers) guards.
A 20 minute minimum
break/meal period is required for
each 7 ½ hours of consecutive
work.



Each violation is a petty offense.
At least 2-times/year, let
Failure to comply may be contempt
employees inspect their files &
Personnel Record of court. Actual damages, costs &
5 or more employees add own statements or rebuttals.
Review Act fees may be awarded. Willful &
Records are documents used for
knowing violations are fineable at
hiring or other personnel actions.
$200/violation.

Guilty of Class A misdemeanor.
Many employers with Employer must pay the state’s Back pay (pay the variance),
Prevailing Wage public works stipulated minimum wage for subject to minimum 20% penalties
Act contracts or work. The wage is set by a & 2% punitive damages. Multiple
subcontracts board. violations may lead to 2-year
debarment.

Can’t discriminate for lawful
activities outside of work. No
Right to Privacy in All employers, inquiry of employee or prior Actual damages, costs & fees
the Workplace except some employers whether employee awardable. If willful violation, then a
Act nonprofits has previously filed a worker’s $200 fine.
compensation claim or
occupational disease claim.

All employers who Employer must pay sales
contract with sales representative according to terms
Sales Up to 3-times the amount owed
people on a of contract, past practice or
Representative (exemplary damages), attorney’s
commission basis; industry custom. Commission
Act fees & court costs.
only covers most must be paid within 13 days of
goods (not services) separation/last day.

Must allow employees who are
elected officials of local
Time Off for government or school board time
Official Meetings All employers off for official meetings None specified
Act (employee must provide advance
notice). No retaliation attending.
Time off can be unpaid.

Upon advance notice, employer
must allow employees to leave
Time-Off for
All employers work for 2-hour period between None specified
Voting
opening & closing of polls to
vote. Can be nonpaid.

Must inform Dept. of Labor &
employees of potential hazards,
safety precautions & emergency
procedures concerning exposure $1k/violation & not more than $10k
5 or more full-time to toxic substances in the for each willful or repetitive violation.
Toxic Substances employees or at workplace which pose known Punitive damages up to 10-times
Disclosure to least 20 full & part suspected health hazards & the total penalty or $20k (whichever
Employees Act time employees which may cause death or is larger). Back pay, attorney fees
more employees serious physical harm. Must & costs. Reinstate employee.
label all toxic substances & train Institute training programs.
all routinely exposed.
Exemptions based on industry,
substances faced & other factors.



Failing to report hires may result in
a penalty equal to the lesser of (a)
$5 for each $10k of the total wages
Must pay unemployment
paid by employer during the period
insurance contributions to IL,
(quarter), or (b) $2,500 for each
Unemployment must file a quarterly Employer’s
All employers month failing to report. Employer
Insurance Act Contribution & Wage Report, &
who willfully fails to pay any
report all new hires within 30
required contribution shall be
days.
required to pay those contributions
plus a penalty equal to 60% of the
amount of the unpaid contributions.

Pay damages equal to the amount
of wages, salary, employment
benefits, public assistance, or other
50 or more Victims of domestic violence, or compensation denied or lost with
Victims’
employees (private household member who is a interest; reinstatement, promotion &
Economic
employers); all state victim, can take up to 12 weeks reasonable accommodations;
Security & Safety
& local public sector of leave during 12-month period. attorney’s fees, expert witness fees,
Act
employers Can be unpaid. Post notice. & other costs of the action; penalty
of 1% per day to the employee for
each day of delay in paying the
damages to the employee.

If employer refuses or neglects to
honor a judicial order, the creditor
Employer must notify employee
may be able to collect the total
Wage Deductions of any withholding/deductions re
amount of the debt, plus fees &
for Benefit of All employers garnishments. Employer must
costs from employer. Employer can
Creditors honor court orders for
be convicted for Class A
garnishments.
misdemeanor for retaliating against
employee due to deductions.

Employers can’t pay minors
under age 18 or women an
Can be convicted of a Class B
Wages of Women oppressive & unreasonable wage
All employers misdemeanor, pay back wages,
& Minors Act (i.e., less than fair & reasonable
attorney’s fees & costs.
for the value of the work & less
than a living wage).

Many federal & state laws
Whistle Blower
prohibit discriminatory or punitive Criminal & civil penalties, including
Statutes (Federal All employers
actions against employees who fines & imprisonment.
& State)
report illegal activities.

All employers who
Employers must insure or self
elect coverage.
insure. Pay disability benefits &
Workers’ Failure to elect (i.e., Any willful neglect or violation is a
expenses for work related
Compensation no insurance) petty criminal offense. Monetary
injuries. Refrain from retaliating
Act exposes employers penalties vary on basis of offense.
against employees for pursuing
to common law
rights under this Act.
liability

DISCLAIMER: THE CONTENT CONTAINED IN THIS DOCUMENT IS GENERAL & INSTRUCTIVE INFORMATION ONLY; IT’S NOT
INTENDED AS LEGAL ADVICE. THIS INFORMATION ISN’T INTENDED TO CREATE & DOESN’T CREATE AN ATTORNEY-CLIENT
RELATIONSHIP. READERS SHOULD NOT ACT UPON THIS INFORMATION WITHOUT FIRST CONSULTING WITH AN ATTORNEY.


Charles Krugels July 22, 2009 City of Chicago Department of Business Affairs Seminar Handout

Charles Krugels July 22, 2009 City of Chicago Department of Business Affairs Seminar Handout

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