Brief Filed for Sex Harassment Class Action Against Aon Subsidiary

May 5, 2003

A brief filed Friday supporting class certification in sexual harassment and discrimination lawsuit against an Aon subsidiary, Combined Insurance Co. of America, included excerpts from 128 declarations signed by former and current women employees who detailed the pervasive discriminatory and sexually charged atmosphere of a "male-dominated institution that allowed discrimination and harassment to run unchecked."

An Aon spokesman called the charges "self-serving and baseless."
Combined sells accident, health, life and disability insurance.

According to their attorneys from Chicago-based law firm Meites, Mulder, Burger & Mollica and Peoria-based law firm Benassi & Benassi, the women worked at a company that "barely pays lip service to its obligation of equal treatment under Title VII, but instead lets the company culture of discrimination flourish despite the real human cost to its female employees." The case, Traci Radmanovich, et al. vs. Combined Insurance Company of America, was filed on Dec. 13, 2001.

In attempting to establishing the need for certification of a class, the brief cites an opinion issued by U.S. District Court Judge James Zagel in a companion case filed by current Combined employee Brenda Palmer. In an opinion issued Feb. 24, 2003, denying Combined's move to strike class allegations, Zagel said the allegations suggest that "embedded within the very foundation upon which Combined rests is a chauvinistic and fundamentally misogynist view of women that is reflected in its company-wide practices and patterns."

The case involves Combined's "Seventh Essential Enhanced Sales Force," which sells health, disability and accident insurance door to door. Complaints include a lack of highly ranked women managers on the sales force, and constant harassment and attacks on women at every level of the company by workers and supervisors. One woman even alleged she was gang raped after a group sales meeting.

Aon spokesman Al Orendorff said "Combined is absolutely dedicated to maintaining a diverse, harassment-free workplace and will not tolerate conduct inconsistent with that policy."

He added that the allegations made in the brief "will be refuted in court where this dispute belongs and not in the press."