Deanna Painter v. Illinois Department of Transp, 16-3187

Deanna Painter, an IDOT office administrator, had repeated coworker complaints about disruptive, intimidating, and erratic behavior after starting in 2010 and again after a 2011 transfer.
IDOT placed Painter on paid administrative leave multiple times and ordered five medical evaluations: two by Dr. Fletcher (occupational medicine), one by Painter’s treating psychologist Dr. Lee, and two by psychiatrist Dr. Killian.
Dr. Fletcher initially cleared Painter but noted possible hypomania and referred her for mental‑health evaluation; Dr. Lee treated Painter and did not report to IDOT.
After renewed complaints in late 2011–2012 (logs of coworkers, late-night emails, reports coworkers feared violence, and a perceived threatening email to a union rep), IDOT sent Painter to Dr. Killian, who first cleared then later found her unfit due to paranoid thinking and disruptive behavior.
Painter sued under the ADA, 42 U.S.C. § 12112(d)(4)(A), alleging the compelled psychiatric examinations (limited on appeal to Dr. Killian’s two exams) were not job‑related or consistent with business necessity.
The district court granted summary judgment for IDOT; the Seventh Circuit affirmed, holding the undisputed record compelled the conclusion the Killian exams were job‑related and consistent with business necessity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether compelled psychiatric exams violated ADA §12112(d)(4)(A)	Painter: Killian’s exams were unnecessary and not job‑related/business‑necessary	IDOT: Objective evidence (coworker statements, emails, disciplinary notes) gave reasonable belief of risk to workplace safety	Affirmed: Exams were job‑related and consistent with business necessity given undisputed record
Whether IDOT must identify a single decisionmaker requiring exams	Painter: Decision‑maker must be identified per Kroll	IDOT: Multiple actors participated; Kroll doesn’t impose an identity requirement	Rejected: No rule requiring a single identifiable decisionmaker in this record
Whether IDOT engaged in improper ‘‘doctor‑shopping’’ to justify firing	Painter: IDOT sought favorable opinions	IDOT: Used same doctors for reevaluations; substitution occurred because Painter continued treatment with Dr. Lee	Rejected: No record support for doctor‑shopping allegation
Whether affidavits contradicting depositions should be struck	Painter: Hunt’s affidavit conflicts with his deposition and should be struck	IDOT: Discrepancies are illusory or explained by memory lapse and are permissible	Rejected/Waived: Painter waived strike request; discrepancies are not material contradictions

Wright v. Illinois Depʹt of Children & Family Servs., 798 F.3d 513 (7th Cir. 2015) (employer bears high burden to show exams are business‑necessary)
Coffman v. Indianapolis Fire Depʹt, 578 F.3d 559 (7th Cir. 2009) (EEOC guidance discussed; safety‑based inquiries may be permissible)
EEOC v. AIC Sec. Investigations, Ltd., 55 F.3d 1276 (7th Cir. 1995) (safe workplace is a paradigmatic business necessity)
Timmons v. Gen. Motors Corp., 469 F.3d 1122 (7th Cir. 2006) (employer need not retain employees who pose safety risk due to disability)
Palmer v. Circuit Court of Cook Cty., 117 F.3d 351 (7th Cir. 1997) (same principle regarding safety and ADA)
Sullivan v. River Valley Sch. Dist., 197 F.3d 804 (6th Cir. 1999) (annoying or inefficient behavior alone does not justify medical exam)
Kroll v. White Lake Ambulance Authority, 763 F.3d 619 (6th Cir. 2014) (employer must have reasonable belief based on objective evidence; does not mandate single decisionmaker)
Russell v. Acme‑Evans Co., 51 F.3d 64 (7th Cir. 1995) (later affidavit may supplement deposition where it augments rather than contradicts)
Beverly v. Abbott Labs., 817 F.3d 328 (7th Cir. 2016) (failure to raise motion to strike in district court waives appellate challenge)