Novak v. Bd. of Trustees of Southern Illinois University

Federal 7th Circuit Court
Civil Court
Americans with Disabilities Act
Citation
Case Number: 
No. 14-2663
Decision Date: 
February 10, 2015
Federal District: 
S.D. Ill.
Holding: 
Affirmed
Dist. Ct. did not err in granting defendant-University’s motion for summary judgment in action under Americans with Disabilities Act and section 502 of Rehabilitation Act, alleging that defendant failed to accommodate plaintiff-student’s post-traumatic stress disorder when it terminated him from its doctoral program. Record showed that defendant had provided reasonable accommodations by giving plaintiff additional time to complete required tests, as well as giving plaintiff multiple opportunities to retake exams, and that termination did not take place until plaintiff had failed certain test four times. Ct., though, emphasized that it owed no special deference to academic decisions when analyzing allegations under discrimination statutes, although it recognized that academic judgments often rest on necessarily subjective judgments about academic potential that are rooted in First Amendment values. In this case, plaintiff failed to show that his evaluators were not involved in bona fide professional assessment of his potential in particular academic program.