Federal 7th Circuit Court
Civil Court
Employment Discrimination
Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in ADA action alleging that defendant violated ADA’s medical record confidentiality requirements by disclosing to potential employers fact that plaintiff had migraine condition. Plaintiff disclosed his migraine condition only after defendant’s management had inquired into plaintiff’s absence from work, and such disclosure was not medical examination and/or inquiry under 42 USC section 12112(d) for purposes of coverage under ADA where management was unaware of plaintiff’s migraine condition at time it inquired into plaintiff’s absence. As such, defendant had no duty to treat its knowledge of plaintiff’s migraine condition as confidential medical record.