Williams v. Board of Education of the City of Chicago, No. 19-3152 (7th Cir. 2020)Annotate this Case
Williams, a Chicago school social worker, suffers from depression, anxiety, and chronic sinusitis. For the 2013–14 school year, Williams received an evaluation score that placed him in the “developing” category, and was given a Professional Development Plan. Social workers' hours depend on the school they are serving on a particular day. The Board denied Williams's first accommodation request, for consistent work hours. During the 2014–15 school year, Williams was cited for interrupting a teacher, failing to read a student’s individual educational plan before a meeting, speaking inappropriately about his personal life, making personal calls during school hours, and failing to report to work. Williams was twice denied titles that may be awarded to “proficient” social workers. Williams filed a discrimination charge and another accommodation request, seeking a consistent start time, a reduced caseload, and assignment to a single school. The Board denied these requests but assigned him to schools with 7:45 a.m. start times. Williams's third accommodation request sought a private office, dedicated equipment, and exemption from evaluations. The Board supplied Williams with HEPA filters, computer monitors, and access to a private meeting space; it denied his other requests. Williams was not selected for special assessment teams because he did not have the “proficient” rating and was not bilingual. He filed his second charge of discrimination.
The Seventh Circuit affirmed the dismissal of his suit under the Americans with Disabilities Act. 42 U.S.C. 12101, and Title VII, 42 U.S.C. 2000e, rejecting claims that the Board discriminated against Williams because of his disability and gender, failed to accommodate his disability, and retaliated against him for filing discrimination claims.