Lee v. Chicago Transit Authority
696 F. App'x 752
| 7th Cir. | 2017Background
- Gregory Lee, a former Chicago Transit Authority (CTA) Transportation Manager, filed suit under the ADA after two episodes of medical leave and two administrative separations for exhausting FMLA leave.
- In 2010 Lee was hospitalized, took short-term disability, was administratively separated when FMLA leave was deemed exhausted, and later was reinstated.
- In 2011 Lee again experienced health problems, took medical leave after another hospitalization, and received a second administrative separation five months later.
- Lee sued alleging the CTA failed to provide reasonable accommodations and terminated him because of a disability; his initial complaints were dismissed and he was given an opportunity to amend.
- The district court dismissed his third amended complaint with prejudice, finding it failed to identify a specific disability or plead that any alleged condition substantially limited a major life activity or that he was qualified for his job with or without accommodation.
- The Seventh Circuit affirmed, holding the operative complaint lacked required factual allegations identifying a disability and showing Lee could perform essential job functions with or without accommodation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lee sufficiently alleged a disability under the ADA | Lee alleges anxiety, depression, sleep apnea, and a prior stroke (causing headaches, concentration and memory problems) | Lee’s operative complaint failed to identify a specific condition or plead how any condition substantially limited a major life activity | No; complaint did not plead a disability as defined by ADA because it lacked factual allegations connecting conditions to substantial limitations |
| Whether Lee alleged he was a "qualified individual" able to perform essential job functions with or without accommodation | Lee contends he was entitled to reasonable accommodation and could perform duties with accommodation | CTA argues complaint lacks allegations that Lee could perform essential functions with or without accommodation | No; Lee failed to allege ability to perform essential functions with or without accommodation |
| Whether the district court imposed an improper heightened pleading standard | Lee argues the court required too much detail about job duties and limitations | CTA contends plaintiff must plead enough facts to put defendant on notice, including specific disability and qualification | Court: Pleading must give fair notice; Lee’s allegations were legally deficient but not because of an improper standard |
| Whether dismissal should be with prejudice after repeated chances to amend | Lee sought further opportunity to cure defects | CTA relied on failure to correct deficiencies after court’s explicit guidance | Dismissal with prejudice affirmed because operative complaint still failed to state an ADA claim |
Key Cases Cited
- W. Bend Mut. Ins. Co. v. Schumacher, 844 F.3d 670 (7th Cir. 2016) (standard for accepting allegations as true on motion to dismiss)
- Tate v. SCR Med. Transp., 809 F.3d 343 (7th Cir. 2015) (elements required to plead an ADA discrimination claim)
- Roberts v. City of Chicago, 817 F.3d 561 (7th Cir. 2016) (ADA pleading and discrimination standards)
- Anderson v. Donahoe, 699 F.3d 989 (7th Cir. 2012) (operative complaint controls on appeal)
- Sinkler v. Midwest Prop. Mgmt. Ltd. P'ship, 209 F.3d 678 (7th Cir. 2000) (definition of disability under ADA and substantial-limitation requirement)