Corporate Death Cut-Off Claims: Oakridge Healthcare and Successor Nonliability

In People ex rel. Department of Human Rights v. Oakridge Healthcare Center, LLC, the Illinois Supreme Court reaffirmed the state’s long-standing rule of corporate successor nonliability, significantly narrowing the circumstances under which plaintiffs may pursue Illinois Human Rights Act claims against a defunct employer’s successor. Rejecting the appellate court’s adoption of a broader federal standard, the Court held that successor liability remains limited to the four traditional exceptions articulated in Vernon v. Schuster, providing greater certainty to corporate purchasers and reinforcing the high bar plaintiffs must clear to establish fraudulent transfer in the employment discrimination context.