Angelina Povey v. City of Jefferson, 697 F.3d 619

Povey, a kennel/adoption attendant at Jeffersonville, injured her right wrist moving a dog in Oct 2007; the job requires lifting objects heavier than 30 pounds for extended periods.
After the injury, HR directed light-duty considerations; Wilder allowed Povey to continue working but limited her duties to cat room/infirmary and exempted weekends, causing co-workers’ schedules to shift.
In May 2008 Povey reported harassment by a coworker and Jeffersonville separated Povey and Hancock locations to minimize friction; an HR investigation found no illegal harassment.
In Aug 2008 Povey received permanent restrictions prohibiting repetitive hand movements and any lifting/ pushing/pulling over five pounds with the right arm; Povey was placed on paid leave and then terminated after a meeting.
Povey filed a complaint with the EEOC alleging disability discrimination and retaliation; the district court granted summary judgment to Jeffersonville, holding Povey not disabled under the ADA; Povey appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Povey is a qualified individual with a disability under the ADA	Povey claims Jeffersonville regarded her as disabled and limited in a broad range of work.	Jeffersonville argues Povey is not disabled and the employer’s statements do not show a broad class limitation.	No; Povey not disabled; statements were about shelter work and do not show a broad class restriction.
Whether Povey was regarded as disabled under the ADA's	Povey relies on statements that she could not perform tasks due to restrictions.	Statements refer to the shelter work only, not a broad range of jobs.	No; insufficient to show regarded-as disability.
Whether Povey could perform the essential functions with accommodation	If disabled or regarded as disabled, she could perform with reasonable accommodation.	No disability found, thus no accommodation obligation.	Not reached given lack of disability.
Whether there is a causal link between Povey’s ADA activity and her termination (retaliation)	Timing and circumstances suggest retaliation for harassment complaints.	Timing alone is insufficient; no causal connection established.	Summary judgment on retaliation affirmed; no nexus shown.

Rockwell Int’l Corp. v. U.S. Fed. Realty, 243 F.3d 1012 (7th Cir. 2001) (evidence needed to show working is a major life activity, requires job-type range data)
Sutton v. United Airlines, 527 U.S. 471 (Supreme Court 1999) (defined 'regarded as' disability and major life activity: working must be substantially limited in a broad class of jobs)
Powers v. U.S.F. Holland, Inc., 667 F.3d 815 (7th Cir. 2011) (significant restriction in ability to perform a class or broad range of jobs to be regarded as disabled)
Squibb v. Memorial Ctr., 497 F.3d 775 (7th Cir. 2002) (demonstrated inability to perform a single, particular job does not render a person substantially limited in working)
Turner v. The Saloon, Ltd., 595 F.3d 679 (7th Cir. 2010) (timing evidence alone insufficient to prove retaliation)