ADA-IHRA

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7^th Circuit Court of Appeals

Case Name: Jeffrey Bruno v. Chasity Wells-Armstrong

Case No.: 22-2945

Officials: Easterbrook, Wood, and Kirsch, Circuit Judges.

Focus: ADA-IHRA

Bruno, a seasoned firefighter from the Kankakee Fire Department, brought a lawsuit against Mayor Chasity Wells-Armstrong, James Ellexson (the Human Resources Director for the City of Kankakee), and the City of Kankakee. Bruno alleged discrimination and retaliation violations under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA). In 2017, Bruno experienced a severe cardiac event and, upon his return to duty, was promoted to Deputy Chief. However, in 2019, he was denied a salary increase and offered an employment contract contingent on his enrollment in college courses for additional compensation. When Bruno, citing his heart condition, requested the removal of this educational requirement, his plea was denied. Subsequently, Bruno signed the contract and retired, commencing legal action.

The Seventh Circuit upheld the district court’s decision, which had granted summary judgment in favor of the defendants. The court determined that Bruno’s request to eliminate the educational requirement did not qualify as a reasonable accommodation under the ADA, as it did not affect his job performance. Additionally, Bruno’s claim of disparate treatment was dismissed since evidence contradicted his pretext argument. His ADA retaliation claim was also dismissed because the activity he identified as protected did not fall under the ADA’s purview. As Bruno’s IHRA and indemnification claims relied on his ADA claims, they too were dismissed.

Affirmed.

Decided 02/23/24

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