Allegations of unpaid wages, denied health insurance coverage, and retaliation following reports of financial misconduct have been brought against a behavioral health services provider by a former program coordinator. The complaint was filed by Megan Apolito in the United States District Court for the Northern District of Illinois on March 18, 2026, naming Bobby E. Wright Comprehensive Behavioral Center, Inc. as the defendant.
According to the filing, Apolito claims that she and other employees were not paid minimum wage for all hours worked in violation of the Fair Labor Standards Act (FLSA), as well as several Illinois state laws including the Illinois Minimum Wage Law (IMWL) and the Illinois Wage Payment and Collection Act (IWPCA). The lawsuit also alleges that Apolito was denied health insurance benefits to which she was entitled under the Employee Retirement Income Security Act (ERISA), and that her employment was terminated in retaliation for engaging in protected activities such as reporting alleged financial improprieties to government authorities.
The complaint outlines that Apolito began working for the defendant as a Program Coordinator on or about September 26, 2023. She states that she received satisfactory feedback during her tenure and was promoted in or around 2024. However, from November 2025 through March 2026, Apolito alleges she experienced repeated delays in payroll alongside other staff members. The document specifies that payments due for December 2025 through February 2026 remained unpaid at the time of filing. It further notes that “in most, if not all work-weeks,” Apolito was not paid at least minimum wage for all hours worked.
Apolito asserts that despite repeated requests to human resources regarding unpaid wages and health insurance coverage—particularly after submitting documentation following her twenty-sixth birthday qualifying life event—her concerns were not addressed by management. She reports being without insurance since August 1, 2025 due to what she describes as a failure by the defendant to process her request or provide necessary follow-up.
The complaint details additional allegations concerning internal financial practices at Bobby E. Wright Comprehensive Behavioral Center, Inc., including claims that while lower-level employees were experiencing missed paychecks, senior executives received substantial wire transfers outside regular payroll systems. Specifically mentioned is a $30,000 transfer to Chief Operating Officer Keenan Holmes in January 2026.
In early February 2026, Apolito filed a formal complaint with the Office of Executive Inspector General for the Agencies of the Illinois Governor (OEIG), citing payroll delays, misappropriation of funds, lack of workers’ compensation benefits for employees, and unethical financial practices within the organization. She received confirmation from OEIG later that month indicating an investigation would be conducted into her allegations.
Less than two weeks after reporting ongoing pay discrepancies to members of the organization’s board—including its chairperson—Apolito’s employment was terminated on or about March 16, 2026 via email from CEO Velma Williams. The stated reason given was organizational restructuring due to financial difficulties; however, Apolito contends this explanation is pretextual and believes her termination resulted from her whistleblowing activities.
The lawsuit sets forth seven counts: violation of FLSA minimum wage provisions; two counts under ERISA related to recovery of benefits and breach of fiduciary duty; violation of IMWL; violation of IWPCA regarding final compensation and accrued leave; retaliatory discharge under Illinois common law; and violation of Illinois’ Whistleblower Act. Citing relevant statutes throughout—including requirements regarding timely payment of wages—the complaint alleges ongoing harm including loss of earnings and employment benefits.
As relief from the court, Apolito seeks back pay with interest, compensation for lost wages and benefits (including front pay), liquidated damages where applicable under statute, compensatory and punitive damages for retaliation claims, reasonable attorneys’ fees and costs associated with litigation efforts, declaratory judgment on ERISA violations by defendant, an order requiring payment of owed benefits under ERISA plans pursuant to federal law provisions cited in the filing (29 USCS §1132(a)(1)(B)), pre-judgment interest if applicable—and any other relief deemed just by the court.
Attorneys Yasmeen Elagha and Mohammed Badwan from Sulaiman Law Group are representing Megan Apolito in this matter before Judge(s) not specified in Case No. 1:26-cv-03068.
Source: 126cv03068_Megan_Apolito_v_Bobby_Wright_Complaint_Northern_District_of_Illinois.pdf