proposed private tort action also fails to meet the “consistency” standard of the second Sawyer factor, in that this statute is not remedial. Finally, and terminally, these Claimants have not persuaded us, and indeed have not offered any cogent argument, that a private damages action is “clearly necessary” or just plain necessary to enforce the governmental non-disclosure policy of this statute. Conclusion and Order Claimants’ petition for rehearing is denied. The order of May 7, 1997, is reaffirmed. ORDER Epstein, J. This cause is before the Court on Claimants’ complaint. This cause was scheduled for hearing before a Commissioner of this Court on May 10, 1999. No one att r implied tort decisions: e.g., Kelsay v. Motorola, Inc. (1978), 74 Ill. 2d 478, 384 N.E.2d 348, 23 Ill. Dec. 554 (<HOLDING>); Hoover v. May Dept. Stores (1979), 77 Ill. 2d
recognizing the tort of retaliatory discharge holding that employee must prove that the sole reason for their discharge was their filing of a workers compensation claim to prevail on a claim of wrongful discharge under marylands workers compensation act recognizing retaliatory discharge tort implied by the workers compensation act recognizing implied private retaliatory discharge action under the guardianship and advocacy act recognizing cause of action for retaliatory demotion for asserting workers compensation rights