Graham v. Arctic Zone Iceplex LLC, No. 18-3508 (7th Cir. 2019)Annotate this Case
In December 2014, Arctic hired Graham as its maintenance supervisor. Arctic soon received customer complaints about his attitude and noticed his insubordination and difficulty completing tasks on time. In February 2015, Graham was injured on the job. He did not work until May and received worker’s compensation. Graham returned to work with medical restrictions requiring that he work sitting down. Arctic assigned Graham to skate sharpening. Graham maintains that the task requires standing but did not inform Arctic of his belief that skate sharpening did not meet his restrictions. When Graham transitioned back to full-time work. Arctic assigned him to work evenings because of seasonal need. Graham characterized this as a “demotion.” In October 2015, Graham caused a Zamboni accident. Arctic claimed that Graham created a hazard to its customers and fired Graham, citing his poor attitude about his position; poor attitude toward customers; lack of timeliness; insubordination; and the Zamboni accident, which caused Arctic to lose revenue. Graham sued, alleging violations of the Americans with Disabilities Act, 42 U.S.C. 12101, by failure to reasonably accommodate his disability and by his termination based on disability. The Seventh Circuit affirmed summary judgment in favor of Arctic. If an employee does not provide sufficient information to determine the necessary accommodations, the employer cannot be held liable for failing to accommodate the disabled employee. Graham did not provide enough evidence to support an inference of bad faith in his termination.