Bailey Conroy v. Board of Education for Cornell Community Consolidated School District No. 426, et al.

Summary

The United States District Court for the Central District of Illinois denies defendants’ motion for summary judgment in Bailey Conroy’s employment-related action. The court finds genuine disputes of material fact concerning whether remote work was a reasonable accommodation under the ADA, whether the stated performance complaints were pretextual, and whether Conroy’s reports to law enforcement were motivating factors in her termination in violation of the First Amendment.

Holdings

1. Summary judgment was denied because Cornell's answer judicially admitted that Conroy was a qualified individual with a disability, and Conroy independently presented evidence creating a genuine factual dispute on that issue.
2. Summary judgment was denied because the evidence created a genuine dispute of material fact as to whether Conroy could temporarily work remotely while performing the essential functions of her position.
3. Summary judgment was denied because the close temporal proximity between Conroy's accommodation request and the solicitation of staff complaints, together with evidence that no prior complaints or performance issues had been documented, created a triable issue as to whether the stated complaints were pretextual.
4. Summary judgment was denied because the evidence created a genuine dispute as to whether Conroy's police reports were at least a motivating factor in the decision to terminate her.
5. Summary judgment was denied because the record and allegations created a triable issue concerning Vincent's personal participation in the alleged First Amendment retaliation.

Questions Presented

1. Whether Defendants were entitled to summary judgment on Conroy's ADA disability-discrimination claim based on her status as a qualified individual and the reasonableness of her requested remote-work accommodation.
2. Whether Defendants were entitled to summary judgment on Conroy's ADA-retaliation claim because no reasonable jury could find a causal connection or pretext between her accommodation request and termination.
3. Whether Defendants were entitled to summary judgment on Conroy's First Amendment retaliation claim under 42 U.S.C. § 1983 because the evidence did not create a triable issue that her police reports were a motivating factor in her termination.
4. Whether Randall Vincent could be held personally liable under § 1983 based on his alleged participation in denying the accommodation, soliciting complaints, compiling them, and recommending termination.

Disposition

other