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Vandeveer v. Fort James Corp.
Citation: 66 F. App'x 16Docket: No. 02-2049
Court: Court of Appeals for the Seventh Circuit; March 11, 2003; Federal Appellate Court
The case originates from Tracey Vandeveer's allegations of sexual-orientation discrimination at Fort James Corporation, where she worked and suffered from multiple sclerosis (MS). Vandeveer claimed that her coworkers' discomfort with her same-sex orientation created a hostile work environment, exacerbating her MS symptoms. After expressing her concerns to human resources, her condition deteriorated, leading to severe incapacitation and inability to work. She sued Fort James under the Americans with Disabilities Act (ADA), asserting that the company failed to accommodate her MS-related limitations by exposing her to a stressful environment filled with anti-lesbian discrimination. The district court granted summary judgment in favor of Fort James, concluding that Vandeveer's MS did not substantially limit her major life activities and therefore did not qualify as a "disability" under the ADA. The court also found that she had not properly notified Fort James of her accommodation needs or identified any reasonable accommodations. On appeal, Vandeveer, representing herself, argued against the district court's findings, stating that her MS significantly limited her activities and that Fort James was aware of her condition and required to inquire about accommodations. However, the appellate court noted that Vandeveer sought an end to the discriminatory environment, which the ADA does not address as it is focused on disabilities rather than sexual orientation discrimination. The court affirmed the district court’s ruling, emphasizing that allowing Vandeveer's arguments could misuse the ADA to challenge any form of discrimination unrelated to disability. The decision underscores that the ADA is intended to eliminate discrimination against individuals with disabilities, not to serve as a means to address workplace discrimination based on sexual orientation.