7th Circuit Affirms Summary Judgment for Employer in Lawsuit under the Americans with Disabilities Act

On January 24, 2020, the 7th Circuit affirmed an order of summary judgment in favor of a defendant-employer in a lawsuit filed under the Americans with Disabilities Act ("ADA").  Youngman v. Peoria County, No. 18-2544 (7th Cir. Jan. 24, 2020).  The plaintiff was placed on medical leave after he informed his supervisor that he could no longer work shifts in the control room.  When changes in job rotations had resulted in his temporary assignment to the control room, he experienced various symptoms.  He requested that he not be assigned to the control room in the future as a reasonable accommodation, but was informed that was not possible.  He was instructed that he could return to work if and when his condition improved.  After his leave time expired, his position was filled, and he filed a lawsuit under the ADA, alleging that the defendant had refused to accommodate his disability and forced him out of his position.  The district court granted summary judgment for the defendant on the ground that the plaintiff was responsible for the breakdown of the interactive process required by the ADA when an employee requests an accommodation.  The 7th Circuit affirmed, but on a different ground.

The ADA provides that no covered entity shall discriminate against a qualified individual with a disability on the basis of disability in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training, and other terms, conditions, and privileges of employment.  Disability discrimination may take the form of treating a disabled employee differently from other employees or failing to make reasonable accommodations to the known limitations of the employee.  The plaintiff alleged a failure-to-accommodate claim.  To prevail, he was required to demonstrate: (1) he was a qualified individual with a disability; (2) his employer was aware of his disability; and (3) the employer failed to reasonably accommodate his disability.  When a qualified employee has requested an accommodation, the ADA requires both parties to engage in an informal interactive process to identify an appropriate accommodation.  The district court found that the plaintiff had failed to provide the necessary clarifications regarding his limitations and ultimately abandoned the interactive process altogether. 

The 7th Circuit concluded that the plaintiff's ADA claim failed on a more basic point.  The ADA prohibits an employer from discriminating against a qualified individual with a disability on the basis of disability.  The failure to accommodate a disabled employee's particular limitation amounts to unlawful discrimination on the basis of disability only if the limitation is caused by the disability.  There must be a causal connection between the major life activity that is limited and the accommodation sought.  A physical or mental condition must substantially limit one or more major life activities to qualify as a disability under the ADA.  There was no causal connection between the plaintiff's condition and the particular limitation for which he sought an accommodation.  He presented no evidence that the symptoms that he suffered when assigned to the control room resulted from his condition.  Absent proof that his symptoms were caused by a condition that qualifies as a disability under the ADA, the plaintiff could not demonstrate that the defendant discriminated against him on the basis of that disability, which is an essential element of his ADA claim.  Thus, summary judgment was proper.