HR exec allegedly assured no retaliation – then came the termination
A lead auditor says she was fired after flagging financial concerns and requesting medical leave, raising questions about how her employer handled both.
Jacqueline Craine has filed suit against Cboe Global Markets, the publicly traded exchange network behind the Chicago Board Options Exchange, accusing the company of retaliating against her for speaking up about accounting irregularities and then denying her request for medical leave. The case, lodged in federal court in Kansas on January 26, offers a cautionary tale for human resources leaders navigating the intersection of whistleblower protections and leave management.
Craine spent nearly three years as a Lead Auditor at Cboe, where she was responsible for testing the company's Sarbanes-Oxley compliance and reviewing internal controls. During that time, she says she uncovered a series of red flags: assets recorded below defined capitalization thresholds, bank reconciliations with gaps exceeding $48 million, absent financial policies for overseas operations, and persistent billing errors affecting customers. According to court filings, her concerns were routinely downgraded to "enhancements" or labeled "immaterial" by leadership.
What makes the case particularly instructive for HR professionals is what allegedly happened next.
In August 2024, Craine brought her concerns directly to Stephanie Foley, the company's Executive Vice President of Human Resources. She wanted to know whether she had an obligation to escalate her findings and whether doing so might put her job at risk. Foley, according to the filing, assured her the company had a clear policy: cooperation was expected, and retaliation against good-faith complaints would not be tolerated.
Cboe referred the matter to outside counsel King & Spaulding LLP to investigate. Craine sat for multiple interviews. But she claims those sessions focused more on her own audit practices than on the issues she had raised. By late December, the firm reported finding no evidence of wrongdoing.
Then came January.
On January 6, 2025, Craine's supervisor announced plans to retire. Her performance review, originally scheduled for mid-month, was pushed back repeatedly. When it finally took place on January 30, she was told her rating would be "expects to see more," disqualifying her from a bonus. Craine responded bluntly: "This is retaliation."
She had, just days earlier, requested leave under the Family and Medical Leave Act for a chest trauma. Minutes after the review ended, her network access was cut. That afternoon, her leave request was denied. The reason given: she was "no longer an employee."
The case remains in its early stages, and no determination has been made on the merits. Craine is seeking back pay, compensatory and punitive damages, and reinstatement.
For HR teams, the timeline alone warrants attention. Whistleblower complaints, internal investigations, performance reviews, and medical leave requests can each carry legal risk on their own. When they collide, as they appear to have here, the stakes multiply.
