164 F. Supp. 3d 1083
C.D. Ill.2016Background
- Meyer worked as a dietician for St. John’s Hospital from April 2010 to July 8, 2014 and has McCune‑Albright syndrome with fibrous dysplasia, requiring use of a wheelchair/crutches and frequent sit–stand rotation.
- In late June/early July 2014 her supervisor Stauffer said Meyer’s workstation would be moved to a smaller shared office and required dietitians to work exclusively from patient floors.
- Meyer asked to continue splitting time between her office and the floor because the floor workstations were too tall and did not allow necessary sit–stand rotation; she requested this as a reasonable accommodation.
- Stauffer reacted angrily and, days after Meyer’s accommodation request, Meyer was terminated on July 8, 2014; employer gave reasons (clinical incompetence, failed chart audit, poor “adaptability”) that Meyer alleges are pretextual.
- Defendant moved to partially dismiss only the ADA failure‑to‑accommodate claim for lack of subject‑matter jurisdiction, arguing Meyer lacks standing and the claim is not ripe because the relocation was never actually implemented.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to bring ADA failure‑to‑accommodate claim | Meyer alleged she requested an accommodation and was terminated as a result, a concrete injury (termination) traceable to employer conduct | No concrete injury because the alleged relocation never occurred, so no need for an accommodation | Court: Meyer pleaded a concrete, non‑speculative injury (termination after accommodation request); she has standing |
| Ripeness of failure‑to‑accommodate claim | Claim concerns an actual adverse action (termination) taken instead of providing an accommodation, not a hypothetical future contingency | Claim is unripe because it rests on a contingent, never‑occurred relocation | Court: Claim is ripe — termination following the accommodation request presents an actual controversy |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (pleading‑stage rule that general allegations of injury can suffice for standing)
- Sierra Club v. Franklin Cnty. Power of Ill., LLC, 546 F.3d 918 (7th Cir. 2008) (standing elements summarized)
- Ctr. for Dermatology & Skin Cancer Ltd. v. Burwell, 770 F.3d 586 (7th Cir. 2014) (12(b)(1) motions test sufficiency of complaint, not merits)
- Hinrichs v. Whitburn, 975 F.2d 1329 (7th Cir. 1992) (ripeness doctrine requires actual, concrete disputes)
- Alicea‑Hernandez v. Catholic Bishop of Chi., 320 F.3d 698 (7th Cir. 2003) (accept well‑pleaded factual allegations and draw inferences for 12(b)(1))