Victoria C. Voegel v. Obstetrics and Gynecology Care Assoc., S.C.

Summary

The United States District Court for the Central District of Illinois considers the defendant employer’s motion for summary judgment in an action alleging disability discrimination and retaliation under the Americans with Disabilities Act and the Illinois Human Rights Act. The court denies summary judgment on the discrimination claims, finding genuine disputes regarding causation and pretext, but grants summary judgment on the retaliation claims.

Holdings

1. No. Genuine issues of material fact exist regarding whether Plaintiff's disability was the 'but for' reason for the adverse employment action, based on both direct evidence (an alleged statement by the employer about getting rid of her due to being a 'fall risk') and circumstantial evidence (potential pretext for the business justification).
2. Yes. Plaintiff failed to establish that she engaged in a statutorily protected activity or a causal connection between any such activity and the adverse employment action.

Questions Presented

1. Whether Defendant is entitled to summary judgment on Plaintiff's claims for disability discrimination under the ADA and IHRA.
2. Whether Defendant is entitled to summary judgment on Plaintiff's claims for retaliation under the ADA and IHRA.

Disposition

other