UPDATE 06/05/2025 Plaintiff filed motion to dismiss Defendant Craig Steinley. I can only assume it's because Appraisal Institute is the one who will end up paying for the lawsuit and damages. There must be a legal, monetary reason for the dismissal. The motion to dismiss is without prejudice so it could be filed again. Maybe she wants to file in a different state or jurisdiction. Maybe she wants to file in federal court because Craig is in a different state than AI. I have no idea.
Activity Date: 06/05/2025 Event Desc: Notice Of Motion Filed Comments: NOM - P's Mtn for Partial Voluntary Dismissal
Activity Date: 06/05/2025 Event Desc: Affidavit Of Service Filed Comments:
Activity Date: 06/05/2025 Event Desc: Notice Filed Comments: NOF - Affidavit of Service
Activity Date: 06/05/2025 Event Desc: Motion Filed Comments: Motion for Leave to Withdraw
Activity Date: 06/05/2025 Event Desc: Notice Of Motion Filed Comments: NOM - Motion for Leave to Withdraw
Activity Date: 06/04/2025 Event Desc: Motion To Dismiss Filed Comments: PLAINTIFF???S MOTION FOR PARTIAL VOLUNTARY DISMISSAL
ORIGINAL: The Ex CEO of the Appraisal Institute Cindy Chance sued the Appraisal Institute and Vice President Craig Steinley under the Whistleblower Act and Illinois Human Rights Act on May 8, 2025 in Circuit Court, Cook County, Illinois case #2025L006066. Chance alleges eight claims of action which include sexual harassment, defamation and retaliation. I'm now following the lawsuit in Pacer. While I was in there I found 21 other lawsuits involving the Appraisal Institute generally as a defendant. I'm sure there are many more in superior court level.
This lawsuit reads like a horror story of alleged acts by Craig Steinley. Based on the lawsuit they should have gotten rid of him a long time ago. Others were protecting and aiding Steinley for their own personal agendas. I had a feeling things like this were probably happening at AI. I just didn't realize it was quite this out in the open and horrible. The lawsuit reads like a nightmare soap opera with back stabbing, manipulation, cronyism and a whole lot of ick.
As a woman in real estate who also had to sue for sexual harassment and unlawful termination I totally feel this situation. I'm sure what actually happened was 100x worse than what is included in the lawsuit. FYI I won my case. I'm pretty sure AI will settle with Cindy Chance so more of this horrible behavior doesn't become public. If this goes to discovery or trial, I predict the end of the Appraisal Institute. They would definitely lose government contracts based on these allegations alone. And to think I almost joined when Cindy was the CEO. I truly thought they were finally on the right track.
Link to Circuit Court page to search for lawsuit. Search law, injury over $30,000 for case number or Cynthia Chance or Appraisal Institute.
https://casesearch.cookcountyclerkofcourt.org/CivilCaseSearchAPI.aspx
Below are just the factual allegations and eight counts.
FACTUAL ALLEGATIONS
10. In or around August of 2023, the consulting and recruiting firm Korn Ferry
concluded an exhaustive national search for AI resulting in the unanimous selection of Chance,
by the Board, to be the next Chief Executive Officer of the Appraisal Institute, a 501(c)(6)
association of real estate appraisers.
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11. AI’s Board of Directors gave Chance a clear mandate to evaluate the state of the
organization and make changes needed to improve the efficiency of operations and to help the
organization meet its education, membership, and financial goals.
12. On or around September 5, 2023, Chance started her role as Chief Executive
Officer (“CEO”) of AI and in or about November 2023, Chance relocated to Chicago for the
position.
13. AI’s Board includes an Executive Committee consisting of the CEO and member
Officers selected by the Board through a nominating process: President, Immediate Past
President, Incoming President, and Vice President. These roles are compensated. The Board
President is effectively the supervisor of AI’s CEO.
14. President Steinley, a paid Executive Officer, and the supervisor of the CEO,
began systematically undermining Chance through a pattern of sexual harassment shortly after
she began working for AI.
15. Chance noticed immediately upon joining AI that the staff organization was
functioning poorly and required reorganization and wholesale cultural change. Employees
reported bullying by other staff, an inability to do or in some cases even understand their jobs,
and a culture of hostility between the National organization and Chapters, among other things.
16. Chance laid off four senior employees on September 27, 2023 to increase the
efficiency of the organization. These four individuals were AI’s Chief Financial Officer Beata
Swacha, its Director of Marketing Erin Tobin, its head of communications Brent Richards, and
its head of education, Sue Sirades. At the time, Chance learned that Steinley had been counseled
due to inappropriate behavior.
17. In or around November of 2023, Chance learned of a complaint by a former
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employee related to sexual harassment.
18. In or around January of 2024 Chance learned of a publicly-filed sexual
harassment lawsuit filed against AI and Steinley.
19. In or around October 2023, Sandra (“Sandy”) Adomatis, incoming 2024 President
of the Board, and Paula Konikoff, Vice President of the Board, told Chance that they both had
witnessed Steinley’s disparagement and disdain for women on many occasions over many years.
Adomatis reported that Steinley had told her directly that he did not trust women and was not
capable of working with her or any woman. Konikoff reported that Steinley had worked for her
and was fundamentally demeaning to women, dishonest, and manipulative.
20. In or around October 2023, Immediate Past President Jody Bishop and Sandy
Adomatis told Chance that Steinley was falsely claiming to have a relationship with Chance,
stating “he’s telling everyone that you are his girlfriend” and that “everyone was talking about it”
or words to that effect.
21. In or around November 2023, Steinley exhibited increasingly manipulative
behavior toward Chance, demeaned Chance, suggested that he had singlehandedly driven change
and she needed to do as he said because without his support, the Board would turn on her and she
would be fired. Steinley suggested to others that he was in a relationship with Chance, arranged
for him and Chance to travel together for business, invited her to personal events, made
inappropriate comments to Chance, told Chance to smile, and commented that Chance’s slacks
“show off [her] fit body.”
22. On numerous occasions, Steinley sent Chance text messages and called her in
which he tried to initiate a personal relationship with her, despite Chance repeatedly rejecting his
advances and telling Steinley that their relationship was strictly professional.
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23. In or around November 2023, Chance heard Steinley say to Mike Mignona,
incoming Vice President, that they were going to “bitch slap her now” referring to Adomatis.
24. On or around November 10, 2023, an AI Board member, Paula Konikoff, told
Chance that she had been the subject of sexual harassment and that the way AI had handled it
had further demeaned her.
25. In or around December of 2023, Steinley commented to Chance that both
Adomatis and Konikoff wanted to sleep with him but could not and this is why they were not
more pleasant to him.
26. Beginning in or around January 2024, Chance reported to AI’s General Counsel
Jeff Liskar that Steinley was acting inappropriately with her, including showing up to events that
she did not expect him to be at and talking about her as if she was his girlfriend. When Chance
reported the foregoing to Liskar, Liskar shook his head and declared, “it’s terrible, it’s terrible,”
referring to Steinley’s mistreatment of Chance.
27. Steinley continued to arrange for him and Chance to travel together for business
in the following months, arranged for him and Chance to sit next to each other at events, stood
inappropriately close to Chance, commented on Chance’s body, and publicly called Chance his
“boss” as one would refer to their wife or partner.
28. About this time, Adomatis explained to Chance that everyone was afraid of
Steinley because he had “a well-deserved reputation for retaliation.”
29. In or around December 2023, Adomatis read a lengthy statement to the Board in
which she complained about the sexism apparent in Steinley’s demeaning treatment of her
related to member leadership assignments stating that Steinley blatantly violated behavioral
standards of leadership in the course of her repeated attempts for a conversation --circumventing
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her authority through sexist manipulation and disparagement.
30. In or around December 2023, Chance heard Mike Mignona and Steinley referring
to Adomatis as “Sandy I’m a dumbass.”
31. In January 2024, Steinley became Immediate Past President, making him
responsible for Chance’s performance evaluation and compensation decisions in her role as
CEO.
32. In or around January 2024, at an AI Officers’ retreat, the Officers jointly agreed—
at Chance’s urging—to implement appraiser-centric messaging and more messaging defending
the appraiser profession to fulfill their mission and support growth. Adomatis repeatedly
expressed support for Chance’s leadership in this regard and AI’s Board and membership
applauded the direction privately and publicly.
33. Following many candid conversations about the culture of harassment and
governance dysfunction, Adomatis encouraged Chance and supported training for the Board,
provided in February 2024, given the urgent need for governance reform to prevent ongoing
harassment, abuse, and lack of fiduciary care on the part of Board members. This was very
negatively received by Steinley who admonished Chance for arranging for such a training.
34. During the February 2024 Board meeting, Chance reported to the Board serious
governance concerns based on that Board members were not acting based on their fiduciary duty
but were acting instead based on tribal allegiances, regional loyalties, and prior agreements.
35. Also, during this Board meeting, Chance reported to the Board that leaders were
misusing complex governance rules (bylaws and “rules and regulations”) as well as “executive
sessions,” preventing open discussion of important issues and depriving members of information
and transparency into the activities of the leadership of the organization.
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36. Steinley continued to regularly tell Chance to “smile” in meetings, “you’re so
much more convincing when you look pretty,” commented on her appearance routinely and now,
including in front of staff and members.
37. In or around February 2024, Adomatis wrote to Chance in response to Steinley’s
decision to campaign for vice president of the Board for another four years leading the
organization as a compensated Officer that “I can’t believe the women that are campaigning for
[Steinley] already. If only they knew,” referring to Steinley and apparently referring to Steinley’s
misconduct with women.
38. On or around February 12, 2024, Chance reported to Adomatis and Liskar in an
email that the same month she started at AI, Steinley and Board members regularly referred to
her as Steinley’s “girlfriend,” contributing to undermining her authority and perpetuating a
hostile environment for women.
39. Steinley continued to try to get Chance to accompany him on travel and referred
to her in emails as his “favorite person” etc.
40. On or around February 13, 2024, Adomatis texted Chance pictures of Steinley’s
campaign materials that he sent to members in his bid for vice president of the Board. Adomatis
was unsupportive of his campaign based on her concerns about his harassment.
41. In or around February 2024, Adomatis arranged a meeting with former president
Rodman Schley. Schley reported to Chance that it was widely known that Steinley harassed
staff. Among other things, Schley told Chance that former AI Chief Executive Officer Jim
Amorin resigned when Steinley became President of the Board because he knew “he would not
be able to protect his staff from Steinley.”
42. Steinley’s “campaign” included demeaning remarks about Chance and outright
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lies about the state of AI’s educational offerings and initiatives. AI advised Chance not to
intervene or remark about Steinley’s false statements regarding education as it was forbidden for
the CEO to do anything that could impact the election of Officers, and she could be fired for
sharing her views with the National Nominating Committee or Board members since this was “a
member level” decision.
43. In or around March and April 2024, a sexual harassment training was provided to
all Board members and to all staff.
44. Following the resolution of a sexual harassment case against AI in or around
April 2024, Chance was required to address, at the direction of the Officers and the Board, a
confidential matter related to a former senior staff member. Steinley’s demeanor toward Chance
changed, and Steinley’s communications ranged from frequent manipulative communications to
not speaking to Chance, which ramped up during this time, as he worked to undermine her
efforts as AI’s CEO.
45. President Sandy Adomatis reported to Chance at this time that Steinley had now
begun telling people that Chance would be “a short-timer,” signaling to Adomatis his efforts to
undermine Chance.
46. In or about May 2024, Chance reported to the Board that AI was providing
inaccurate state certification information due to haphazard organizational practices. Chance
reported that these deficiencies required urgent correction as they were creating ongoing
problems for professional certifications.
47. In or about May 2024, Chance reported to the Board that AI had been
intentionally overstating membership numbers to shield itself from membership challenges
regarding its management.
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48. In or about May 2024, Chance reported to the Board that the President and other
Officers were ensuring lucrative teaching opportunities for their friends and themselves. Chance
reported that this practice had caused a notable decline in both the quality and diversity of AI's
educational offerings and compromised the integrity of what constituted excellence in education.
49. In or about May 2024, Chance reported concerns to the Board that AI’s instructor
"approval" process was effectively discriminatory against women and other minority candidates
by disproportionately rejecting women and other minority candidates from becoming instructors,
who were otherwise well qualified or preventing qualified people from gaining teaching
assignments. A member of the Education Committee put together a report showing this impact
that was shared with Liskar, Steinley, and the Chair of the Education Committee at the time.
50. In or about May 2024, and following the hiring of a new Director of Education
and Publications, Chance reported to the Officers and the Board serious issues concerning its
education and testing, including an incident where education staff admitted to haphazardly
adding examination questions resulting in significant issues with incorrect answers.
51. On or around May 15, 2024, Steinley succeeded in his aim to be nominated again
to be Vice President of the Board, by the “National Nominating Committee,” which Chance
learned from Board members was a committee selected based on systems of fealty and political
allegiances as with other leadership positions at AI.
52. Chance and the entire Board were informed by internal counsel that it was
forbidden to discuss Steinley’s successful nomination with members following the May
recommendation of the National Nominating Committee, and until after the vote of the Board in
August.
53. During the May 2024 Board meeting, it was reported to the Board that a
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confidential matter related to a former employee alleging sexual harassment had been resolved as
per their direction.
54. On or around May 15, 2024, Chance reported to AI’s Board that there were
instances of sexual harassment within the organization, leaving the organization vulnerable to
risk. While having had individual conversations with Board members about Steinley, Chance
was reluctant to name Steinley as the perpetrator by name in her report since it was clear that
Steinley’s behavior was being discussed, and Steinley was sitting right next to her during the
meeting, scowling at Chance, ignoring Chance, and intimidating Chance. Chance did continue to
speak with people individually about Steinley’s abuse following these remarks.
55. In response to, and during Chance’s remarks to the Board, Steinley threatened
Chance.
56. Shortly after the Board meeting, and following Steinley’s intimidating email, and
just before a live and recorded Q and A with members, Steinley groped Chance’s rear while he
and Chance were walking alone down a hallway at AI’s office. Prior to groping Chance, Steinley
said, “what if I grabbed your butt.” He then groped Chance without her consent.
57. After Steinley groped Chance, he again tried to arrange travel for him and
Chance. However, Chance refused to travel again with Steinley.
58. In or around May/June of 2024, President Sandy Adomatis spoke with every
Board member and reported formally to Chance to provide a review of how the Board meetings
went and that they appreciated her work and the information provided at the May 2024 Board
meeting. “The only critical remark” was that a few Board members reported that there was too
much information provided.
59. Through May of 2024 and into the summer, President Sandy Adomatis made
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numerous highly supportive public comments about Chance’s leadership.
60. In or around June of 2024, Chance wrote three appraiser-centric messages
reflecting member concerns with Appraisal Management Companies business practices, which
drew strong comments from Adomatis and Steinley to the effect that Chance should stop talking
about Appraisal Management Companies s. Steinley wrote that Chance’s writing had caused the
Real Estate Valuation Advocacy Association “REVAA", the advocacy organization for
Appraisal Management Companies, to rescind their endorsement of his nomination for Vice
President.
61. Steinley insisted, and the Officers agreed, to force Chance to attend a meeting
with the AMC lobbying organization, REVAA, senior executives of AMCs, and all AI executive
Officers, in August 2024, just before the AI Board meeting, to “educate her properly” on the
AMC business model. Those AMC senior executives were later among those saying Chance
would imminently be fired.
62. In or around June of 2024, Chance began scheduling meetings with each of the
Board members to review the health of the organization.
63. Chance spoke with AI’s Board members between June of 2024 and August of
2024, and Chance reported to various AI Board members, including Adomatis, Don Boucher,
Elaine Ramirez, and Heather Mull, that Steinley was sexually harassing her, undermining her,
and retaliating against her.
64. On or around June 18, 2024, AI’s Audit Co-Chairs, Mike Tankersley, and Richard
Wolf contacted Chance requesting certain information including intrusive and exceptionally
unusual inquiries about staff. Chance objected and the AI committee told Chance in writing to
“watch her tone” and to remember that “as soon as you leave this room that we will have all the
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power over you.”
65. On or around May 2024, Adomatis told Chance that they must pursue every legal
means to prevent Steinley from rejoining the organization as an officer again based on his
harassment of women.
66. In or around May 2024, Konikoff had a verbal altercation with Steinley at a
public event related to his behavior toward her.
67. In or around August 2024, AI Board member Elaine Ramirez told Chance that
Steinley was controlling of women and that AI’s Board had a history of issues with sexism and
corruption for many years. Ramirez told Chance that she had real concerns about female
employees at AI being marginalized and she witnessed AI employing its Audit Committee to use
force to undermine people such as women, LGBTQ+ individuals, and outsiders. Ramirez also
told Chance that she thought that members of AI’s Board were undermining Chance and treating
her in a way that was far worse than their treatment of males, based on her observations in the
Audit Committee Meeting.
68. In or around August 2024, AI Board member Heather Mull told Chance that
Steinley had been sexually inappropriate with her and that she felt uncomfortable because of
Steinley’s sexual harassment. Mull asked Chance to help facilitate an open discussion with the
Board about sexual harassment issues that should preclude Steinley from continuing on the
Board and to ensure that Steinley could not become an officer again because of his sexual
misconduct. Chance again reported to Mull that Steinley was also sexually harassing Chance.
Mull reported to Chance that Board members were fearful of confronting Steinley based on
retaliation including using proxies.
69. On or around August 15, 2024, Chance reported to AI’s Board again that there
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were serious issues related to sexual harassment, bullying, and culture during an in-person Board
meeting. Board member Rob Elliott responded by asking, “why do you keep telling us things we
already know?”
70. In or about August 2024, Chance reported to the Board that Officers and staff
were deliberately concealing the poor performance of a high profile, major investment aimed at
growing revenue while “diversifying the profession,” Practical Applications of Real Estate
Appraisal. Chance explained that the best course of action was to tell members the truth about
the failure of this investment while shrinking or eliminating the program. Chance believed that
this concealment violated the organization's obligation to inform members about material
business losses and undermined diversity initiatives.
71. On or around August of 2024, AI’s Board re-elected Steinley to an officer
position; Steinley was elected Vice President of the Board. Adomatis facilitated the election of
Steinley by not following the protocol that had been provided by Chance, which recommended
Adomatis to ask Steinley to leave the room to allow for open discussion by the Board of this
nomination as Vice President as well as instruction to the Board that they did not need to accept
this recommendation.
72. On or around August 16, 2024, Joan Barngrover, AI’s special assistant to the
CEO and Board Secretary told Chance that the Officers were “horrible people” referring to their
abuse of Chance and protection of one another from the consequences of their malfeasance.
Barngrover also noted that meeting notes were not accurately representative of their meetings,
nor of all of their meetings.
73. In August 2024, Chance reported to the Board that Officers were attempting to
prevent her from addressing harmful practices by appraisal management companies that were
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damaging members' livelihoods and undermining appraisal quality nationwide.
74. On or around August 15, 2024, and August 16, 2024, Steinley as Immediate Past
President led a process described as a “performance evaluation” of Chance. By phrasing the
process as a performance evaluation, Steinley became in charge of the process and ensured that
Chance could not be in the room to address the Board.
75. At one point during the two-day meeting, Chance was called in and asked
questions including one about a July 11, 2024 meeting she participated in with the Consumer
Financial Protection Bureau, which included two appraisers who had been collecting information
as whistleblowers. The purpose of the meeting was to express serious issues for consumers in
this profession accountable to the public trust, including AMCs acting as middlemen and
pocketing a significant percentage of each appraisal fee reported to consumers, the degradation
of data on appraisals, and the impact of ongoing self-dealing within the industry, recognized by
Director Chopra in public statements.
76. During the purported performance evaluation, Board members asked the Officers
whether they had a responsibility to act based on the fact that Chance had been alerting them to
concerns about sexual harassment that needed to be addressed. Adomatis shared with the Board
that she had no reason to believe there had been sexual harassment at AI despite her many claims
to the contrary to Chance, Liskar, Konikoff, and many others.
77. On or around August 18, 2024, the Board’s Officers presented Chance with a list
of “Directives” undermining her ability to function as CEO including instruction to
“Immediately stop all media communication that is not in compliance with the Executive
Officers’ email to you dated August 4, 2024” which stated “We unequivocally ask you for two
weeks’ lead time to evaluate and collaborate with you on future “From Cindy’s Desk” messages.
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This courtesy shall also be extended to website messages and posts, membership-wide emails,
and all similar outward-facing messaging prior to posting/publication… (cont.)” and also to
“discontinue making disparaging remarks, verbally and/or in writing, about the organization, its
governance or staff, such as and including, but not limited to, labeling the Board of Directors,
Executive Officers, and the organization as political and dysfunctional.”
78. On or around August 18, 2024, Chance began hearing from members that AI
Officers were planning to terminate her. On or around September 3, 2024, the President of the
Board called a special Board meeting to continue the “performance evaluation” led by Steinley,
at which there was an attempt to remove Chance as AI’s Chief Executive Officer, but the effort
failed because of objections by some Board members and a public campaign of member support
based on the widespread rumors, which Adomatis and Steinley denied publicly.
79. On or around September 7, 2024, the new CFO/COO, John Udelhofen, who is
currently serving as Acting CEO/CFO/COO sent a letter to Chance notifying her that the
behavior of the Officers and the Board is bordering on financial fraud and that it is apparent that
she is being bullied. On or around September 10, 2024, Chance wrote in her update to the Board:
As a reminder, I offered a stern warning at the Q2 Board meeting
following the [resolution of confidential former personnel claim] I made
clear to the full Board my concerns about the risk of the ongoing culture
that represented a grave risk to the organization.
I made clear, more explicitly still, at the start of the Q3 Board meeting that
we were trying to work within a culture of sexism and abuse and selfdealing.
This has not been discussed with me to date. My concerns seem
to have been dismissed or ignored or addressed through sanctions against
me in the form of Directives.
80. On or around September 10, 2024, and September 11, 2024, Adomatis announced
another special Board meeting from which Chance would be recused under the pretext that the
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Board would discuss her performance. Neither the Board nor Chance ever received any
presentation on Chance’s performance or a performance evaluation from Steinley.
81. On or around September 12, 2024, AI’s Board held a special meeting to discuss
Chance’s “recent communications,” which centered around her formal written and verbal
warnings to the Officers and Board regarding the ethical and legal risks of their present course,
including repeated inappropriate and discriminatory behaviors. The Board then approved
terminating Chance’s employment “without cause.”
82. On or around September 12, 2024, the Board notified Chance by email that she
was “terminated without cause.” The Board told Chance that she could resign by September 13,
2024, at 10:00 a.m. in lieu of termination.
83. Chance immediately began receiving and continued to receive reports from
individuals that Steinley, Konikoff, Adomatis, and others falsely told Board members, AI
members, and the public that Chance “embezzled $1M”, that Chance “sold our body of
knowledge to a for-profit competitor,” that there was "something that [AI] should have come out
in her background check was discovered,” that “the staff needed to be protected from her,” that
“if you knew what she did, you’d understand [the reasons for her termination].”
84. Chance has sustained economic damages and mental anguish as the result of
Defendants’ actions, and she will continue to sustain damages into the future.
THE EIGHT COUNTS
COUNT I
Illinois Human Rights Act
775 ILCS 5/1-101 et seq.
Sexual Harassment
Against All Defendants Jointly and Severally
85. Plaintiff hereby incorporates all allegations set forth in the foregoing paragraphs
as though fully alleged herein.
86. Plaintiff was an employee as defined in 775 ILCS 5/2-101(A).
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87. Defendant AI is an employer as defined in 775 ILCS 5/2-101(B).
88. Defendant Steinley is an employee as defined in 740 ILCS 174/5.
89. Defendants subjected Plaintiff to sexual harassment as defined in 775 ILCS 5/2-
101(E).
90. Defendants violated 775 ILCS 5/2-102(D) when Steinley engaged in sexual
harassment of Plaintiff.
91. Plaintiff has sustained damages as the result of Defendants’ illegal sexual
harassment in violation of the Illinois Human Rights Act, including, but not limited to, damage
to her career and emotional and mental distress.
92. Plaintiff is entitled to such legal or equitable relief as will effectuate the purposes
of the statute, including, but not limited to, a cease and desist order; actual damages; a civil
penalty; reasonable costs and attorneys’ fees; a compliance report; posting of notices; and any
such action as may be necessary to make Plaintiff whole.
COUNT II
Illinois Human Rights Act
775 ILCS 5/1-101 et seq.
Retaliation
Against All Defendants Jointly and Severally
93. Plaintiff hereby incorporates all allegations set forth in the foregoing paragraphs
as though fully alleged herein.
94. Plaintiff was an employee as defined in 740 ILCS 174/5.
95. Defendant AI is an employer as defined in 740 ILCS 174/5.
96. Defendant Steinley is an employee as defined in 740 ILCS 174/5.
97. Defendants are person as defined in 775 ILCS 5/1-103(L).
98. Defendants subjected Plaintiff to retaliation as defined in 775 ILCS 5/6-101(A).
99. Plaintiff engaged in protected activity when she reported Steinley’s sexual
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harassment of her and other women at AI and the sexism present at AI.
100. Plaintiff reasonably and in good faith believed that Steinley’s sexual harassment
was prohibited by the Illinois Human Rights Act.
101. Defendants violated 775 ILCS 5/6-101 when it retaliated against her by
undermining her, issuing directives to her, and ultimately terminating her employment because
of her protected activity.
102. Plaintiff has sustained damages as the result of Defendants’ illegal retaliation in
violation of the Illinois Human Rights Act, including, but not limited to, damage to her career
and emotional and mental distress.
103. Plaintiff is entitled to such legal or equitable relief as will effectuate the purposes
of the statute, including, but not limited to, a cease and desist order; actual damages; a civil
penalty; reasonable costs and attorneys’ fees; a compliance report; posting of notices; and any
such action as may be necessary to make Plaintiff whole.
COUNT III
Illinois Whistleblower Act
740 ILCS 174/1 et seq.
Against Defendant AI
104. Plaintiff hereby incorporates all allegations set forth in the foregoing paragraphs
as though fully alleged herein.
105. Plaintiff was an employee as defined in 740 ILCS 174/5.
106. Defendant AI is an employer as defined in 740 ILCS 174/5.
107. Defendant AI took retaliatory action against Plaintiff as defined in 740 ILCS
174/5 when it issued directives to Plaintiff and ultimately terminated her employment.
108. 740 ILCS 174/15(c) prohibits an employer from taking retaliatory action against
an employee for disclosing or threatening to disclose to any supervisor, principal officer, board
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member, or supervisor information related to an activity, policy, or practice of the employer if
the employee has a good faith belief that the activity, policy, or practice “(i) violates a State or
federal law, rule, or regulation or (ii) poses a substantial and specific danger to employees, public
health, or safety.”
109. Plaintiff reported to Defendant AI’s Board members and General Counsel that
Steinley, an AI officer, was sexually harassing her.
110. Plaintiff had a good faith belief that Steinley’s sexual harassment of her violated
the Illinois Human Rights Act, 775 ILCS 5/2-102 et seq., and posed a substantial and specific
danger to employees.
111. Plaintiff reported to Defendant AI's Board members that AI was providing
inaccurate state certification information through haphazard organizational practices. Plaintiff
had a good faith belief that this practice violated requirements of the Illinois Department of
Financial and Professional Regulation and similar regulations in other states.
112. Plaintiff reported to Defendant AI's Board members that Officers were
deliberately overstating membership numbers to shield themselves from accountability for
organizational decline. Plaintiff had a good faith belief that this practice violated reporting
requirements established by the Illinois Attorney General's Charitable Trust Bureau and IRS
annual reporting mandates for 501(c)(6) organizations.
113. Plaintiff reported to Defendant AI's Board members that Officers, particularly the
Board President, were improperly influencing teaching appointments to benefit themselves and
their associates, resulting in diminished educational quality and diversity. Plaintiff had a good
faith belief that this practice violated Federal anti-discrimination laws, Illinois human rights
laws, and professional standards required by the Illinois Department of Financial and
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Professional Regulation.
114. Plaintiff reported to Defendant AI's Board members that AI's instructor approval
and hiring practices were systematically discriminatory and were creating barriers that
effectively prevented qualified women and other candidates from securing instructor positions.
Plaintiff had a good faith belief that this practice violated the Illinois Human Rights Act, 775
ILCS 5/2-102 et seq.,
115. Plaintiff reported to Defendant AI's Board members that AI's testing materials
contained questions with incorrect examination answers. Plaintiff had a good faith belief that this
practice violated professional standards required by the Illinois Department of Financial
Professional Regulation and comparable regulatory bodies.
116. Plaintiff reported to Defendant AI's Board members that Officers were attempting
to prevent her from addressing harmful practices by appraisal management companies that
damaged members' livelihoods and undermined appraisal quality. Plaintiff had a good faith
belief that this practice violated consumer protection regulations established by the CFPB and
SEC, as well as anti-trust laws.
117. Plaintiff reported to Defendant AI's Board members that Officers and staff were
deliberately concealing the poor performance of Practical Applications of Real Estate Appraisal
(“ PAREA”). Plaintiff had a good faith belief that this practice violated the organization's
obligation to inform members about material business losses and requirements established by the
Illinois Secretary of State's Business Services Department and Illinois Attorney General for
501(c)(6) organization.
118. Defendant AI violated 740 ILCS 174/15(c) when it retaliated against Plaintiff for
her disclosures of sexual harassment and illegal organizational practices.
21
119. As a result of Defendant AI’s violations of the Whistleblower Act, Plaintiff has
suffered and is continuing to suffer injuries, including, but not limited to, damage to her career,
damage to her professional reputation, damage to her personal reputation, emotional distress, and
mental distress.
120. For Defendant AI’s unlawful retaliation against Plaintiff in violation of the
Whistleblower Act, Plaintiff is entitled to such legal or equitable relief as will effectuate the
purposes of the statute, including, but not limited to, reinstatement at the same seniority status
Plaintiff would have had but for the violation; back pay, with interest; and compensation for any
damages sustained as a result of the violation, including litigation costs, expert witness fees, and
reasonable attorneys’ fees.
COUNT IV
Defamation Per Se
Against Defendant AI
121. Plaintiff hereby incorporates all allegations set forth in the foregoing paragraphs
as though fully alleged herein.
122. Under Illinois common law, an employer is prohibited from engaging in
defamation per se. Green v. Rogers, 234 Ill. 2d 478, 488, 917 N.E. 2d 450, 457 (2009).
123. Defendant AI has engaged in defamation per se when it has told Board members,
organization members, and the general public that Plaintiff “embezzled $1M”, that Plaintiff “sold
our body of knowledge to a for-profit competitor,” that there was "something that [AI] should
have come out in her background check was discovered,” that “the staff needed to be protected
from her,” that “if you knew what she did, you’d understand [the reasons for her termination].”
124. As a result of Defendant AI’s defamatory statements, Plaintiff has suffered and is
continuing to suffer injuries, including, but not limited to, damage to her career, damage to her
professional reputation, damage to her personal reputation, emotional distress, and mental
22
distress.
125. For Defendant AI’s unlawful defamation, Plaintiff is entitled to such available
legal or equitable relief, including, but not limited to, nominal damages, general damages, and
reasonable costs and attorneys’ fees.
COUNT V
Negligent Hiring
Against Defendant AI
126. Plaintiff hereby incorporates all allegations set forth in the foregoing paragraphs
as though fully alleged herein.
127. Under Illinois common law of negligent hiring, an employer becomes liable for
an employee’s torts if (1) the employer knew or should have known that the employee had a
particular unfitness for the position so as to create a danger of harm to third persons; (2) such
particular unfitness was known or should have been known at the time of the employee's hiring;
and (3) this particular unfitness proximately caused the plaintiff's injury.
128. Defendant AI’s Board member and Officer, Steinley, sexually harassed and
physically sexually assaulted Plaintiff.
129. Defendant AI negligently hired Steinley as immediate past President of the Board
and Vice President of the Board, despite Defendant AI knowing that Steinley had sexually
harassed Plaintiff and other women within the organization.
130. Defendant AI owed a duty of care to Plaintiff as Plaintiff’s employer.
131. Defendant AI knew or reasonably should have known at the time of Defendant
AI’s hiring of Steinley as immediate past President and Vice President that Steinley had a
particular unfitness for the position that created a danger of harm to third persons because
Plaintiff reported to Board members and Defendant AI’s General Counsel that Steinley had
sexually harassed her and other women within the organization.
23
132. Steinley’s unfitness for the position was the proximate cause of Plaintiff’s injury
because Steinley sexually harassed Plaintiff.
133. As a result of Defendant AI’s negligent hiring, Plaintiff has suffered and is
continuing to suffer injuries, including, but not limited to, damage to her career, damage to her
professional reputation, damage to her personal reputation, emotional distress, and mental
distress.
134. For Defendant AI’s negligent hiring, Plaintiff is entitled to such available legal or
equitable relief, including, but not limited to, nominal damages, general damages, and reasonable
costs and attorneys’ fees.
COUNT VI
Negligent Retention
Against Defendant AI
135. Plaintiff hereby incorporates all allegations set forth in the foregoing paragraphs
as though fully alleged herein.
136. Under Illinois common law of negligent retention, an employer becomes liable for
an employee’s torts if (1) the employer knew or should have known that the employee had a
particular unfitness for the position so as to create a danger of harm to third persons; (2) such
particular unfitness was known or should have been known at the time of the employee's
retention; and (3) this particular unfitness proximately caused the plaintiff's injury..
137. Defendant AI’s Board member and Officer, Steinley, sexually harassed and
physically sexually assaulted Plaintiff.
138. Defendant AI negligently retained Steinley as immediate past President of the
Board and Vice President of the Board because Defendant AI knew that Steinley had sexually
harassed Plaintiff and other women within the organization yet allowed him to continue with the
organization.
24
139. Defendant AI owed a duty of care to Plaintiff as Plaintiff’s employer.
140. Defendant AI knew or reasonably should have known at the time of Defendant
AI’s retention of Steinley as immediate past President and Vice President that Steinley had a
particular unfitness for the position that created a danger of harm to third persons because
Plaintiff reported to Board members and Defendant AI’s General Counsel that Steinley had
sexually harassed her and other women within the organization.
141. Steinley’s unfitness for the position was the proximate cause of Plaintiff’s injury
because Steinley sexually harassed Plaintiff.
142. As a result of Defendant AI’s negligent retention of Steinley, Plaintiff has
suffered and is continuing to suffer injuries, including, but not limited to, damage to her career,
damage to her professional reputation, damage to her personal reputation, emotional distress, and
mental distress.
143. For Defendant AI’s unlawful negligent retention of Steinley, Plaintiff is entitled to
such available legal or equitable relief, including, but not limited to, nominal damages, general
damages, and reasonable costs and attorneys’ fees.
COUNT VII
Negligent Supervision
Against Defendant AI
144. Plaintiff hereby incorporates all allegations set forth in the foregoing paragraphs
as though fully alleged herein.
145. Under Illinois common law of negligent supervision, an employer becomes liable
for an employee’s torts if the employer failed to reasonably supervise an offending employee.
146. Defendant AI’s Board member and Officer, Steinley, sexually harassed and
physically sexually assaulted Plaintiff.
147. Defendant AI had a duty to supervise Steinley because he was an Officer of the
25
organization.
148. Defendant AI negligently supervised Steinley because Defendant AI knew that
Steinley had sexually harassed Plaintiff and other women within the organization yet did not
supervise him to the extent that they could stop Steinley’s sexual harassment.
149. Steinley’s sexual harassment of Plaintiff was generally foreseeable because
Plaintiff reported to Board members and Defendant AI’s General Counsel that Steinley had
sexually harassed her and other women within the organization.
150. Defendant AI’s failure to supervise Steinley was the proximate cause of
Plaintiff’s injury because Steinley sexually harassed Plaintiff.
151. As a result of Defendant AI’s negligent supervision of Steinley, Plaintiff has
suffered and is continuing to suffer injuries, including, but not limited to, damage to her career,
damage to her professional reputation, damage to her personal reputation, emotional distress, and
mental distress.
152. For Defendant AI’s unlawful negligent supervision of Steinley, Plaintiff is
entitled to such available legal or equitable relief, including, but not limited to, nominal damages,
general damages, and reasonable costs and attorneys’ fees.
PRAYER FOR RELIEF
Plaintiff prays this Honorable Court for the following relief:
A. Judgment against Defendants in an amount of damages to be determined at trial;
B. Pre-judgment interest;
C. Economic damages including front pay and back pay;
D. Compensatory and punitive damages;
E. Interest due on unpaid wages;
26
F. Reasonable attorneys’ fees and the cost of this action;
G. Reasonable expert witness fees; and
H. Any other relief this Honorable Court deems just and proper to award.
JURY DEMAND
Plaintiff demands a jury for all issues proper to be so tried.
Dated: May 8, 2025 Respectfully submitted,
DOCKET
Case Number Calendar Date Filed Division
2025L006066 LCALY 05/08/2025 District 1
Plaintiff(s) Case Type Defendant(s) Attorney
CYNTHIA CHANCE
Statutory Action - Jury APPRAISAL INSTITUTE
CRAIG STEINLEY
THALIA PACHECO-DE LOERA
Ad Damnum
0
Future Court Activity:
Court Date: 07/07/2025 Hearing Type: First Time Case Management First Time Case Management(Judicial Officer:Schneider, Catherine,Calendar, Y) Time: 9:00 AM Location: Court Room 2004,Richard J Daley Center
Case Activities:
Activity Date: 05/08/2025 Event Desc: New Case Filing Comments:
Activity Date: 05/08/2025 Event Desc: Statutory Action Complaint Filed (Jury Demand) Comments: Civil Cover Sheet, Complaint, and Jury Demand
Mary Cummins of Cummins Real Estate is a certified residential licensed appraiser in Los Angeles, California. Mary Cummins is licensed by the California Bureau of Real Estate appraisers and has over 35 years of experience.
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