By: Derek Hawkins//May 2, 2016//
7th Circuit Court of Appeals
Case Name: Barbara J. Wells v. Winnebago County, Illinois
Case No.: 15-1805
Officials: BAUER, EASTERBROOK, and HAMILTON, Circuit Judges.
Focus: Discrimination
Summary judgment properly granted against appellant for discrimination claims.
“She needed to establish that the County was required to treat her references to anxiety as notices of a link between her disability and her working conditions that would set off the process of considering possible accommodations. Even in this litigation she has not offered medical evidence demonstrating that a reasonable employer would understand every mention of an employee’s anxiety as a disability or understand, without medical knowledge, how anxiety and chronic fatigue syndrome are related. Certainly Wells did not provide such evidence to her employer. “[O]ur cases have consistently held that disabled employees must make their employers aware of any nonobvious, medically necessary accommodations with corroborating evidence such as a doctor’s note or at least orally relaying a statement from a doctor, before an employer may be required under the ADA’s reasonableness standard to provide a specific modest accommodation”. Ekstrand v. School District of Somerset, 583 F.3d 972, 976 (7th Cir. 2009).”
Affirmed