Suzanne Parker v. Brooks Life Science, Inc., 39 F.4th 931

Suzanne Parker, a part-time receptionist with multiple sclerosis and sciatica, worked ~25 hours/week at Brooks Life Science and had received SSDI benefits since 2005–06.
Brooks’s PTO policy required prior manager approval for planned time off and entry of PTO into Workday; supervisors exempted very short adjustments (Williams used a 30‑minute threshold).
Williams (new supervisor, Mar 2018) coached Parker repeatedly about PTO/schedule changes; HR met with Parker in May 2018 to review the policy.
On October 8, 2018, Parker emailed to request leaving early for pain treatment (protected ADA activity); Williams approved but instructed Parker to put the time in PTO/Workday and later learned employees had covered shifts while Williams was away.
Williams met with Parker Oct. 10 about unapproved schedule changes, recommended termination in an email to HR that day, and Brooks terminated Parker Oct. 11, 2018.
Parker sued for ADA retaliation; the district court granted summary judgment for Brooks, and the Seventh Circuit affirmed, finding insufficient evidence of a causal ("but‑for") link or of pretext.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Parker presented sufficient evidence that her October 8 accommodation request caused her termination ("but‑for" causation)	Parker: close temporal proximity (decision to terminate two days after request; termination three days after) supports inference of retaliation	Brooks: contemporaneous reports of PTO violations and prior months of coaching break causal link; termination motivated by repeated PTO policy violations	Held: Timing plus record shows intervening event (reported PTO violations) — suspicious timing alone is insufficient; no genuine dispute of material fact on causation.
Whether Brooks’s stated reason (PTO violations) was pretextual	Parker: supervisor emails show praise for swapping shifts and inconsistent statements; HR’s incorrect unemployment statement shows shifting narratives	Brooks: the emails concern unplanned absences or small adjustments consistent with policy; the unemployment form was filled out by an uninvolved HR official and is irrelevant to decisionmaker’s belief	Held: Emails, read in context, are consistent with Brooks’s PTO rules; no evidence that decisionmakers gave a false reason.

Joll v. Valparaiso Cmty. Sch., 953 F.3d 923 (7th Cir. 2020) (de novo review standard for summary judgment).
Scott v. Harris, 550 U.S. 372 (U.S. 2007) (view facts in light most favorable to nonmovant).
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment requires more than a scintilla of evidence).
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (plaintiff must show an essential element on which it bears the burden).
Kotaska v. Fed. Express Corp., 966 F.3d 624 (7th Cir. 2020) (elements of ADA retaliation claim, including but‑for causation).
Ortiz v. Werner Enters., Inc., 834 F.3d 760 (7th Cir. 2016) (consider the evidence as a whole in retaliation cases).
Rowlands v. United Parcel Serv.–Fort Wayne, 901 F.3d 792 (7th Cir. 2018) (applying Ortiz to ADA retaliation).
Monroe v. Ind. Dep’t of Transp., 871 F.3d 495 (7th Cir. 2017) (examples of circumstantial evidence of causation).
Coleman v. Donahoe, 667 F.3d 835 (7th Cir. 2012) (suspicious timing plus other evidence can preclude summary judgment).
Sklyarsky v. Means‑Knaus Partners, L.P., 777 F.3d 892 (7th Cir. 2015) (suspicious timing alone rarely establishes causation).
Ineichen v. Ameritech, 410 F.3d 956 (7th Cir. 2005) (pretext inquiry focuses on whether employer’s reason was a lie, not whether it was harsh).
Marnocha v. St. Vincent Hosp. & Health Care Ctr., Inc., 986 F.3d 711 (7th Cir. 2021) (identify weaknesses or inconsistencies making employer’s reason unworthy of credence).