Frazier-Hill v. Chicago Transit Authority, No. 22-1609 (7th Cir. 2023)
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Frazier-Hill was terminated from her employment as a CTA bus driver. She sued, alleging that the CTA failed to provide her a reasonable accommodation in violation of the Americans with Disabilities Act, 42 U.S.C. 12101 (ADA). Specifically, she claimed that the CTA should have allowed her to drive only standard, non-articulated buses due to certain maladies caused by her carpal tunnel syndrome.
The district court granted the CTA summary judgment. The Seventh Circuit affirmed. No reasonable jury could find that Frazier-Hill was disabled within the meaning of the ADA. The court noted that Frazier-Hill had surgery that relieved her carpal tunnel symptoms; a medical report from her physician about three months after her operation and five days before one of her accommodation requests indicated no work restrictions other than a temporary inability to drive articulated buses. The doctor declined to check any of the boxes indicating that Frazier-Hill was restricted in, for example, lifting, pushing, walking, bending, carrying, pulling, or stooping. An occupational therapy report also noted no deficits in lifting.
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