Taylor-Novotny v. Health Alliance Med. Plans, Inc., No. 13-3652 (7th Cir. 2014)
Annotate this CaseTaylor-Novotny sued her former employer, Health Alliance Medical Plans under the Americans with Disabilities Act, 42 U.S.C. 12101, the Family and Medical Leave Act (“FMLA”), 29 U.S.C. 2601-2654, and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000. She contended that Health Alliance failed to accommodate her multiple sclerosis as the ADA required, discriminated and retaliated against her based on her disability, interfered with her FMLA rights, and discriminated against her based on her race. She also asserted a state law claim of intentional infliction of emotional distress. The district court granted summary judgment for Health Alliance. The Seventh Circuit affirmed. Taylor-Novotny did not establish that she was disabled within the meaning of the ADA and did not meeting Health Alliance’s legitimate expectations for punctuality and accountability. Her failure to meet Health Alliance’s legitimate expectations also foreclosed her race discrimination claim. With respect to her ADA failure-to-accommodate claim, she did not establish that the additional accommodation that she sought was reasonable. The evidence was insufficient to form a convincing mosaic suggesting that Health Alliance retaliated against her because she sought accommodations for her multiple sclerosis. Health Alliance never denied Taylor-Novotny FMLA leave.
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