By: Derek Hawkins//May 14, 2018//
7th Circuit Court of Appeals
Case Name: Rasul Freelain v. Village of Oak Park, et al.
Case No.: 16-4074
Officials: WOOD, Chief Judge, and EASTERBROOK and HAMILTON, Circuit Judges.
Focus: FMLA and ADA Violation
Plaintiff Rasul Freelain worked as a police officer in the Village of Oak Park, Illinois for five years before he claims another officer began harassing him. After an incident in 2012 prompted him to report the misconduct, Freelain began experiencing migraine headaches and other medical conditions that he has attributed to stress related to the harassment. To deal with these medical issues, Freelain took significant periods of time off work.
As Freelain began taking time off, tensions rose between him and the police department. Freelain claims that as a result of his medical condition and use of leave time, the village retaliated against him in violation of the Family and Medical Leave Act, 29 U.S.C. § 2601 et seq., and the Americans with Disabilities Act, 42 U.S.C. § 12101 et seq. The district court granted summary judgment in favor of the village on all claims. We affirm. The undisputed facts show that the acts that Freelain has identified as retaliation would not discourage a reasonable employee from exercising his or her rights under these statutes.
Affirmed