Maksimovic v. Tsogalis

Must a claim of intentional tort related to allegations of sexual harassment be litigated before the Illinois Human Rights Commission (the Commission), or, stated differently, does the exclusive remedy provision of the Illinois Human Rights Act (Act) (775 ILCS 5/8— 111(C) (West 1994)) divest the circuit court of jurisdiction to adjudicate such common law tort claims? This court visited this question in Geise v. Phoenix Co. of Chicago, Inc., 159 Ill. 2d 507, 517 (1994), and held that where a tort claim is "inextricably linked” to claims of sexual harassment such that there is "no independent…