Law School Case Brief
Richardson v. Chi. Transit Auth. - Nos. 17-3508, 18-2199, 2019 U.S. App. LEXIS 17597 (7th Cir. June 12, 2019)
The Americans with Disabilities Act of 1990 (ADA) prohibits employers from discriminating against a qualified individual on the basis of disability. 42 U.S.C.S. § 12112(a). To succeed on an ADA claim, an employee must show: (1) he is disabled; (2) he is otherwise qualified to perform the essential functions of the job with or without reasonable accommodation; and (3) the adverse job action was caused by his disability.
In an action filed in federal district court, plaintiff Mark Richardson, a former bus operator for defendant Chicago Transit Authority ("CTA") bus operator, alleged that CTA took adverse action against him because of his extreme obesity in violation of the Americans with Disabilities Act of 1990 ("ADA"), 42 U.S.C.S. §§ 12101-12213, as amended by the ADA Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553. The district court disagreed. It held extreme obesity only qualified as a disability under the ADA if it was caused by an underlying physiological disorder or condition. The court granted CTA's motion for summary judgment because Richardson offered no such evidence. Richardson appealed that holding, as well as the district court's decision to tax costs against him.
Was Richardson's extreme obesity an actual impairment under the ADA?
The court sided with three other federal circuit courts of appeal that had confronted the issue and ruled that extreme obesity only qualified as a disability under the ADA if it was caused by an underlying physiological disorder or condition, and Richardson offered no such evidence, nor did he present sufficient evidence to permit a reasonable jury to infer that CTA perceived his extreme obesity was caused by an underlying physiological disorder or condition. The court further ruled that the district court did not err in taxing costs against Richardson under Fed. R. Civ. P. 54(d)(1) as it provided an explanation for its award and was not required to explicitly consider Richardson's indigence.
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