Reeves ex rel. Reeves v. Jewel Food Stores, Inc., 759 F.3d 698

Sean Reeves, an employee with Down syndrome, worked as a bagger for Jewel from 1997 until his termination in April 2005.
Jewel provided individualized training, a job coach early on, and special supervision measures (daily evaluations sent to Reeves’s parents; exemption from some tasks).
Reeves engaged in several workplace rule violations (cursing at managers/customers; a mistaken taking of a flag pin).
After the flag-pin incident Reeves’s mother asked whether a job coach could be brought back; the supervisor declined and no coaching was provided.
Reeves was later terminated for cursing at a coworker in front of customers; he filed an EEOC charge and received a Right-to-Sue notice.
The district court granted summary judgment for Jewel, dismissing Reeves’s failure-to-accommodate claim (initially calling it waived); the Seventh Circuit affirmed on the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Reeves waived failure-to-accommodate claim by not naming it in the complaint	Reeves pleaded facts showing discrimination under the ADA, which includes failure to accommodate; that suffices to preserve the claim	Jewel argued the claim was not pled and thus waived	Court: No waiver — pleading facts, not legal labels, is enough, so claim preserved
Whether Jewel failed to reasonably accommodate Reeves’s disability after the flag-pin incident	Reeves (via his mother) contends a job coach was requested and would have prevented later misconduct, so Jewel failed to accommodate	Jewel says it did provide many accommodations, declined the belated job-coach request, and the request did not sufficiently identify an accommodation for future outbursts	Court: No reasonable-accommodation failure — request was limited, Reeves’s mother did not engage in the interactive process or propose alternatives, and the employer cannot be held liable when employee (or guardian) doesn’t supply needed information

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
Bunn v. Khoury Enters., Inc., 753 F.3d 676 (7th Cir. 2014) (summary judgment review)
Ekstrand v. Sch. Dist. of Somerset, 583 F.3d 972 (7th Cir. 2009) (elements of failure-to-accommodate claim)
Basden v. Prof'l Transp., Inc., 714 F.3d 1034 (7th Cir. 2013) (interactive process requirement)
Bultemeyer v. Fort Wayne Cmty. Schs., 100 F.3d 1281 (7th Cir. 1996) (both parties’ role in identifying accommodations)
Beck v. Univ. of Wis. Bd. of Regents, 75 F.3d 1130 (7th Cir. 1996) (employer not liable if employee fails to provide sufficient information)
Hatmaker v. Mem’l Med. Ctr., 619 F.3d 741 (7th Cir. 2010) (pleading facts, not legal theories, suffices)