Richardson v. Chicago Transit Authority, No. 18-2199 (7th Cir. 2019)Annotate this Case
Richardson began working for CTA in 1993. Richardson weighed 350 pounds in January 2005 and weighed 566 pounds in May 2009. Richardson suffers from hypertension and sleep apnea. In 2010, Richardson was absent from work because he had the flu. CTA’s medical provider documented that could not return to work until he controlled his blood pressure. CTA transferred Richardson to Temporary Medical Disability. When Richardson was physically fit to work, he had to be cleared for safety because CTA bus seats are not designed for drivers weighing over 400 pounds. Assessment instructors noted that: Richardson had his foot on the gas and brake at the same time; Richardson was unable to make hand-over-hand turns; Richardson’s leg rested close to the door handle; Richardson could not see the floor from his seat; part of Richardson’s body hung off his seat and the seat deflated when Richardson sat. Richardson was “sweating heavily,” needed to lean onto the bus for balance, and had a “hygiene problem.” CTA proposed to return Richardson to disability to work with doctors to lose weight; Richardson would release his ability to bring various claims. Richardson refused. In 2012, CTA terminated his employment. The district court rejected Richardson’s claim under the Americans with Disabilities Act, 42 U.S.C. 12101–12213. The Seventh Circuit affirmed; extreme obesity only qualifies as a disability under the ADA if it is caused by an underlying physiological disorder or condition. Richardson offered no such evidence.
The court issued a subsequent related opinion or order on August 2, 2019.