Youngman v. Peoria County, No. 18-2544 (7th Cir. 2020)
Annotate this CaseYoungman, a Peoria County Juvenile Center counselor, was diagnosed with a pituitary tumor and acromegaly in 1993 and had surgery to remove the tumor and part of his pituitary gland. He had a thyroidectomy in 2011, resulting in hypothyroidism and hypocalcemia. The Center’s superintendent reviewed the rotation of assignments and decided that every counselor needed to be trained in and rotated through all assignments, including the control room. Youngman had only worked in the control room on 10-14 occasions during his 13 years at the Center. Youngman was assigned to work in the control room for a week in 2012 but was not told that this was for training purposes and would only be temporary. Youngman informed his supervisor that he could no longer work in the control room because he experienced headaches, nausea, and dizziness. He was placed on medical leave and instructed that he could return to work when his condition improved. After Youngman’s leave time expired, his position was filled; he found employment elsewhere. He filed suit under the Americans with Disabilities Act, alleging that his employer had refused to accommodate his disability. The district court granted the defendants summary judgment. The Seventh Circuit affirmed, citing the lack of proof of a causal nexus between Youngman’s hypothyroidism and the limitation for which he sought an accommodation.
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