Sara Helton v. Illinois Secretary of State

Summary

The United States District Court for the Central District of Illinois addresses cross-motions for summary judgment in Sara Helton’s ADA action against the Illinois Secretary of State. The court concludes that training other employees was an essential function of Helton’s Drivers Facility Manager I position and that her requested accommodation—being excused from training—would not permit her to perform that function. The court grants the defendant’s motion for summary judgment and denies Helton’s partial motion for summary judgment.

Holdings

1. Training other employees was an essential function of Plaintiff's Drivers Facility Manager I position.
2. Plaintiff was not a qualified individual under the ADA because she was medically unable to perform the essential function of training employees and did not identify an accommodation that would allow her to perform that function.
3. Defendant was entitled to summary judgment on all ADA claims because Plaintiff could not establish that she was a qualified individual able to perform the essential functions of her position.

Questions Presented

1. Whether Defendant was entitled to summary judgment on Plaintiff's ADA claims because Plaintiff could not perform the essential functions of her Drivers Facility Manager I position with or without reasonable accommodation.
2. Whether employee training was an essential function of Plaintiff's position.
3. Whether Plaintiff's proposed accommodation of being excused from training would allow her to perform the essential functions of her job.
4. Whether Plaintiff was entitled to partial summary judgment on her ADA claims.

Disposition

other