Feld, Steven v. Dejoy, Louis, 3:23-cv-00641

Steven Feld, a former USPS city carrier assistant, alleged disability discrimination and failure to accommodate his knee injury, leading to his resignation.
Feld’s supervisor, Postmaster Brown, was notified of Feld’s medical restrictions and instructed Feld not to exceed them; Brown accommodated Feld’s documented needs.
Feld voluntarily returned to work and performed his duties, sometimes working overtime and handling heavier packages than his restrictions allowed.
A co-worker, Woloszyn (not Feld’s supervisor), publicly berated Feld about his work performance, which upset Feld and led to his subsequent absence and communication expressing intent to resign.
Feld never explicitly requested further accommodations or reported any supervisor’s failure to accommodate after his initial restrictions were addressed.
The court accepted defendant’s proposed facts as undisputed due to Feld’s noncompliance with procedural rules for summary judgment opposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonable accommodation	Brown did not provide needed light duty; led to constructive discharge	Feld’s restrictions were fully accommodated; no unmet requests	Defendant's motion for summary judgment granted
Disparate treatment/discriminatory termination	Feld was fired for pretextual reasons due to his disability	Feld resigned voluntarily; no evidence of adverse action for disability	Defendant's motion for summary judgment granted
Hostile work environment/harassment	Hostile environment by co-worker forced resignation	Any harassment was by a co-worker, not supervisor; not reported to Brown	No basis for employer liability; claim fails
False reason for resignation	Files say Feld resigned due inability to get along, which is false	Feld’s resignation followed a documented breakdown with Woloszyn, substantiating records	Court found no evidence of pretext or discriminatory intent

Allen-Noll v. Madison Area Tech. Coll., 969 F.3d 343 (7th Cir. 2020) (locally required procedural compliance for summary judgment responses)
Smith v. Lamz, 321 F.3d 680 (7th Cir. 2003) (failure to properly respond to statements of fact is an admission)
Brumfield v. City of Chicago, 735 F.3d 619 (7th Cir. 2013) (elements of a reasonable accommodation claim under the Rehabilitation Act)
Severson v. Heartland Woodcraft, Inc., 872 F.3d 476 (7th Cir. 2017) (definition of reasonable accommodation and essential job functions)
Yochim v. Carson, 935 F.3d 586 (7th Cir. 2019) (burden on plaintiff to show face-value reasonableness of accommodation request)
Ford v. Marion Cnty. Sheriff’s Off., 942 F.3d 839 (7th Cir. 2019) (employer liability standard in co-worker harassment cases)
Swain v. Wormuth, 41 F.4th 892 (7th Cir. 2022) (disparate treatment, adverse employment action by reason of disability)
Anderson v. Donahoe, 699 F.3d 989 (7th Cir. 2012) (plaintiffs may not amend their complaint by summary judgment briefing)