Ford v. Marion County Sheriff's Office, No. 18-3217 (7th Cir. 2019)Annotate this Case
Ford had worked as a Deputy Sheriff for several years when another driver crashed into her patrol vehicle, severely injuring Ford’s dominant right hand. She has not regained use of her hand and suffers sometimes-debilitating pain. The Sheriff’s Office placed Ford on light-duty tasks for a year. Ford physically could not resume her work as a deputy and was purportedly told that she could either accept a civilian position with a pay cut, resign, or be fired. Ford requested Americans with Disabilities Act, 42 U.S.C. 12101 accommodations: a hands-free telephone, voice-activated software, an ergonomic work station, the ability to take breaks when needed for pain, and training for her supervisors. Each request, except the voice-activated software, was granted. Ford accepted a civilian position. Ford alleges that she then suffered three years of disability harassment. The Office transferred two workers, of whom Ford complained. Ford had multiple complaints about other co-workers. The Office switched Ford from a fixed to a rotating schedule. Ford unsuccessfully requested to be returned to a fixed schedule, saying that the rotating schedule exacerbated her complex regional pain syndrome, attaching a physician’s note to that effect. Ford unsuccessfully applied four times to be transferred or promoted before she secured a transfer to the violent-offender registry, where she continues to work.
The Seventh Circuit affirmed the rejection of most of Ford’s discrimination claims on summary judgment. A district court may properly separate claims based on specific adverse employment actions, retaliation, denial of reasonable accommodation, and hostile work environment. On her demotion claim, Ford failed to present evidence that some vacant job existed closer to her original job, rendering the visitation clerk demotion unreasonable. There were no material disputes of fact as to the promotion decisions.