Parker v. Brooks Life Science, Inc., No. 21-2415 (7th Cir. 2022)
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Parker suffers from MS and sciatica and has received social security disability benefits for that diagnosis for several years. Brooks hired Parker in 2017. Parker worked as a receptionist 25 hours per week (usually mornings). Parker had different supervisors and received mixed feedback on her performance. Parker had to be “coached” concerning her use of paid time off (PTO). In 2018, Parker requested time off to get treatment for pain. Her supervisor, Williams, learned that during Williams’ absence, Parker had taken unapproved time off and made schedule changes. Williams approved the requests but warned that Parker was exceeding her PTO. Parker acknowledged that she needed to do a better job complying with the policy. Williams understood Parker’s statements to be admissions and emailed HR employees, recommending termination. After receiving their assent, Williams informed Parker that she was being terminated. Brooks apparently told the Indiana Department of Workforce Development that Parker had voluntarily quit to accept other employment. In response to her EEOC complaint, Brooks stated that its reason for terminating Parker was repeated failure to follow established PTO policies.
In a suit under the Americans with Disabilities Act, 42 U.S.C. 12101, the Seventh Circuit affirmed summary judgment in favor of Brooks. Parker did not produce evidence that would allow a reasonable juror to infer a link between her request for accommodation (time off for pain treatment) and her termination.
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