Narrative Opinion Summary
In this case, a former housekeeping assistant claimed that her employer, Northwestern Hospital, violated the Americans with Disabilities Act (ADA) by failing to accommodate her asthma condition and not engaging in an interactive process for accommodations. She alleged that her condition worsened over time, leading to severe work restrictions. Despite her efforts to seek reasonable accommodations, the hospital continued to assign tasks that exacerbated her asthma. Ultimately, she was unable to work and applied for Social Security disability benefits. She filed discrimination charges with the Illinois Department of Human Rights and the EEOC, but the district court granted summary judgment in favor of the hospital, ruling that her claims were time-barred. The court found that she was not a 'qualified individual with a disability' under the ADA during the critical 300-day period, as she had been unable to work since May 2009. The court also determined that the continuing-violation doctrine did not apply, as the alleged failures to accommodate were discrete acts rather than ongoing policies. Thus, her federal lawsuit was dismissed, leaving her without the relief she sought for back pay, front pay, and damages.
Legal Issues Addressed
Americans with Disabilities Act - Qualification as a Qualified Individualsubscribe to see similar legal issues
Application: The court held that Teague was not a 'qualified individual with a disability' during the relevant time period due to her inability to perform any job functions since May 2009.
Reasoning: The district court sided with Northwestern, ruling that Teague's claims were time-barred as she was not a qualified individual during the relevant 300-day period, as her inability to work in any capacity began in May 2009.
Continuing Violation Doctrinesubscribe to see similar legal issues
Application: The continuing-violation doctrine was deemed inapplicable as Teague failed to demonstrate an ongoing policy or timely violation.
Reasoning: The court denied Teague's ADA claim, determining that the continuing-violation doctrine was inapplicable because she did not demonstrate a timely violation.
Employer's Duty to Accommodate under the ADAsubscribe to see similar legal issues
Application: Teague failed to establish that Northwestern was liable for not engaging in an interactive process as she did not show the existence of a suitable vacant position.
Reasoning: Even if Teague could establish that she was a qualified individual with a disability, she failed to prove that Northwestern was liable for not engaging in an interactive process to accommodate her.
Failure to Accommodate as a Discrete Actsubscribe to see similar legal issues
Application: The court noted that failures to accommodate are discrete acts and do not constitute a continuing violation.
Reasoning: Previous court decisions classified failures to accommodate as discrete acts, further undermining Teague’s argument.
Statute of Limitations under the ADAsubscribe to see similar legal issues
Application: Teague's claims were dismissed for being outside the 300-day filing limit for EEOC charges, which started on August 2, 2009.
Reasoning: The court reinforced that in Illinois, a discrimination charge must be filed with the EEOC within 300 days of the alleged conduct, starting on August 2, 2009.