Brooks v. City of Pekin

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment on plaintiffs-one police officer’s Americans with Disabilities (ADA) claim and another’s officer’s Title VII claim. With respect to ADA claim record showed that plaintiff sought transfer of shifts as accommodation for his sleep apnea, but that defendant offered other accommodations such as naps during plaintiff’s shift. Dist. Ct. could properly find no ADA violation where: (1) defendant satisfied duty to explore range of accommodations with plaintiff; and (2) plaintiff could not demand shift transfer, where plaintiff’s physician drafted note indicating that plaintiff could do job with or without accommodation. Also, Dist. Ct. could properly reject ADA retaliation claim, where plaintiff’s placement on leave of absence was based on plaintiff’s misconduct in workplace. With respect to plaintiff-officer’s Title VII retaliation claim for making prior protest of sexual harassment, Dist. Ct. could properly find that plaintiff had not engaged in protected activity, where plaintiff could not show that he held sincere and reasonable belief that he was challenging conduct that violated Title VII, where complaints of sexual harassment concerned only crude inquiries by co-workers about identities of women plaintiff was dating. As such, Ct. of Appeals concluded that plaintiff had not shown anything other than he had encounters with co-workers, who had either personal animosity against him or had exhibited juvenile behavior.