Rehabilitation Act-Race Discrimination (Title VII & §1981)-Employment Law

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7^th Circuit Court of Appeals

Case Name: Keisha Lewis v. Indiana Department of Transportation

Case No.: 25-1776

Officials: Brennan, Chief Judge, and Rovner and Hamilton, Circuit Judges.

Focus: Rehabilitation Act-Race Discrimination (Title VII & §1981)-Employment Law

The found Lewis was employed by the Indiana Department of Transportation (Department), where she managed federal relocation claim vouchers for individuals displaced by highway construction projects. After being granted a remote-work accommodation for a kidney-related medical condition, Lewis began experiencing ongoing disputes with her supervisors concerning her assigned duties, work performance, and adherence to job requirements. Tensions increased when she refused to process certain vouchers and failed to follow supervisory directives, which contributed to a backlog exceeding 400 parcels. Although she was warned that failure to fulfill her responsibilities would constitute insubordination, Lewis continued to challenge her obligations and was ultimately terminated for poor performance and insubordination.

Following her termination, Lewis filed a lawsuit against the Department and two supervisors, alleging disability discrimination and retaliation under the Rehabilitation Act, along with race discrimination and retaliation under Title VII and 42 U.S.C. § 1981. Several claims were later voluntarily dismissed, and the Southern District of Indiana granted summary judgment in favor of the defendants on the remaining claims, finding that no reasonable jury could rule in Lewis’s favor.

Lewis appealed the decision, and the Seventh Circuit reviewed the district court’s ruling de novo. The court determined that claims under the Rehabilitation Act require proof that disability was the sole cause of the adverse employment action, a burden Lewis failed to satisfy. The court also found no evidence of pretext or retaliatory motive in her termination. Additionally, her race discrimination and retaliation claims were unsuccessful due to insufficient supporting evidence and waiver of certain arguments.

Affirmed.

Decided 04/22/26

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