Summary
This Seventh Circuit opinion affirms the district court's grant of summary judgment in favor of Chicago State University against a former pharmacy student alleging disability discrimination under Section 504 of the Rehabilitation Act and the ADA. The court concluded that the plaintiff failed to meet the program's academic requirements after failing two mandatory clinical rotations, despite receiving reasonable accommodations. Additionally, the record lacked evidence that the university's dismissal decision was pretextual or motivated solely by her disabilities. The appellate court upheld the dismissal, emphasizing that institutions are not required to lower legitimate academic standards to accommodate students.
Topics
Practice areas
Questions Presented
- Whether Royan presented sufficient evidence that she was otherwise qualified to continue in CSU's Doctor of Pharmacy program under Section 504.
- Whether Royan presented sufficient evidence that CSU's stated academic reasons for dismissing her were pretextual.
- Whether Royan presented sufficient evidence that CSU dismissed her solely by reason of her disabilities.
- Whether the district court properly granted summary judgment to CSU on the Rehabilitation Act claim.
Holdings
- Royan was not otherwise qualified under Section 504 because she failed two clinical rotations that she was required to pass to continue and graduate from the program.
- Royan did not create a genuine dispute that CSU's stated reason for dismissal—her failure of two clinical rotations—was dishonest or pretextual.
- Royan failed to present evidence from which a reasonable jury could find that CSU dismissed her solely because of her disabilities.
- Summary judgment was proper because no genuine dispute of material fact existed concerning whether Royan was otherwise qualified, whether CSU's academic reasons were pretextual, or whether CSU dismissed her solely because of her disabilities.
Key quotations
“The Rehabilitation Act protects individuals with disabilities from discrimination based on those disabilities. It does not, however, exempt students from meeting legitimate academic standards.” (2)
“Our precedent makes clear that the Rehabilitation Act’s causation standard is more stringent than the ADA’s “but for” inquiry.” (19)
“At bottom, Royan’s theory rests on conjecture. But conjecture, without supporting evidence, is not enough to defeat summary judgment.” (23)
Factual background
Royan was enrolled in CSU's four-year Doctor of Pharmacy program and disclosed clinical depression, an eating disorder, and other medical conditions to CSU personnel. CSU provided accommodations, including extensions and a medical leave, but Royan failed a clinical rotation with Dr. Patel after performance concerns and her withdrawal from the rotation, then failed a second clinical rotation with Dr. Kerner. After the second failure, CSU's Academic Standing Committee dismissed her under its academic policies; the record showed that Dr. Kerner was unaware of Royan's disabilities when he evaluated and failed her.
Procedural history
Royan sued CSU and Gentry, alleging that her dismissal from CSU's pharmacy program violated Section 504 of the Rehabilitation Act and the ADA, and that Gentry violated her Fourteenth Amendment due process rights under 42 U.S.C. § 1983. The district court granted defendants summary judgment on all claims. Royan appealed only the summary judgment ruling on her Rehabilitation Act claim against CSU. The Seventh Circuit affirmed.