Khan v. Midwestern University, 147 F. Supp. 3d 718

Ayesha Khan enrolled at Midwestern University medical school in 2010 and became pregnant in Feb. 2013; she experienced fatigue, nausea, anxiety, and gestational diabetes and sought academic accommodations.
Her physician provided a note stating she was being treated for depression and anxiety related to pregnancy and was "unable to fulfill the academic responsibilities."
Khan missed time, requested schedule/rotation/exam accommodations, was denied a rescheduling of a Pharmacology final after pregnancy-related symptoms and failed the course.
Midwestern dismissed Khan from the medical program in May 2013; the dismissal was upheld after appeal.
Khan sued alleging (1) race/national-origin discrimination under Title VI and (2) disability discrimination under Section 504 of the Rehabilitation Act; she abandoned any Title IX claim.
The University moved for judgment on the pleadings under Rule 12(c); the Court granted judgment for defendant on the Title VI claim (with prejudice to further amendment) and denied judgment on the Rehabilitation Act claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Khan pleaded intentional race or national-origin discrimination under Title VI	Khan alleges Midwestern refused reasonable accommodations because she is an American of Indian descent	Midwestern argues the complaint contains only conclusory allegations and no facts showing intentional discrimination	Court: Dismiss Title VI — plaintiff failed to plead facts permitting an inference of intentional discrimination (judgment for defendant)
Whether pregnancy-related impairments constitute a "disability" under Section 504/ADA definition	Khan alleges pregnancy-related conditions substantially limited her ability to learn/attend school and produced a doctor’s note stating she could not fulfill academic responsibilities	Midwestern contends the impairments were temporary and not substantially limiting	Court: Denied judgment on the pleadings — temporary/episodic impairments can qualify; allegations and medical note suffice at pleading stage
Applicability of federal financial assistance element (Title VI / Rehab Act)	Implied: Midwestern receives federal funds (pleading alleges recipient status)	Defendant did not contest recipient status on this motion	Court: Recipient status not disputed and not dispositive on these pleadings
Whether plaintiff may amend Title VI claim further	Plaintiff had prior chance to amend	Defendant seeks final resolution	Court: Title VI dismissal with prejudice as to further amendment

McReynolds v. Merrill Lynch, 694 F.3d 873 (7th Cir. 2012) (pleading standard for intentional discrimination claims)
Adams v. City of Indianapolis, 742 F.3d 720 (7th Cir. 2014) (Rule 12(c)/(b)(6) pleading plausibility standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations insufficient to survive pleadings challenge)
Grzan v. Charter, 104 F.3d 116 (7th Cir. 1997) (elements of Rehabilitation Act claim)
Heatherly v. Portillo’s Hot Dogs, Inc., 958 F. Supp. 2d 913 (N.D. Ill. 2013) (effects of a shorter-term high-risk pregnancy can be substantially limiting under ADA regs)
Alexander v. Sandoval, 532 U.S. 275 (2001) (Title VI requires proof of intentional discrimination)