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In Weiler v. Household Finance Corp., the district court held that (1) the plaintiff was not disabled under the ADA; (2) the defendant reasonably accommodated the plaintiff; and (3) the ADA does not support claims of supervisor liability.
In 1987, Weiler began work for Household Finance Corp. (HFC). In 1991, she became Manager of Branch Accounting, where Skorupka was her supervisor. In 1992, Weiler was diagnosed with temporal mandibular joint dysfunction and ccasionally left work early for treatment of this condition. In February 1993, Weiler met with Skorupka to review her performance. During the meeting, Skorupka allegedly became loud and defensive, causing Weiler severe stress and anxiety. After the meeting, she requested a transfer to another supervisor. She was informed that she could transfer through an internal procedure known as "posting."
In March 1993, Weiler's doctor informed HFC that she was suffering from anxiety and depression and could not return to work. Weiler was placed on short-term disability until September 1993, when her leave expired. HFC applied for long-term benefits, but its insurer denied the application because Weiler was "not unable" to work. HFC supplied Weiler with several postings in her grade level. Weiler did not apply for any of the positions and asserted that she was unable to work for HFC, which considered her to have voluntarily terminated her employment. In May 1993, Weiler filed an EEOC complaint, and filed suit in district court within the proper time, naming HFC, its parent company and Skorupka as defendants. The defendants moved for summary judgment.
The district court noted that because Weiler did not file EEOC complaints against Skorupka and the parent company, they were not properly included as defendants in her suit. Thus, they were dismissed. The court also noted that even if Skorupka was a party to the suit, he would not be liable for "supervisor liability," as the ADA does not permit such liability.
Turning to substantive issues, the district court noted that to prevail under the ADA, Weiler must show that: (1) she was disabled under the ADA; (2) she is qualified, with or without reasonable accommodation, to perform the essential functions of the job; and (3) that she suffered adverse employment action due to her disability. The ADA defines "disability" as including "a physical or mental impairment that substantially limits one or more major life activities of the individual." Major life activities include activities such as caring for one's self, performing manual tasks, walking, seeing, hearing, and working.
The court found the main issue to be whether Weiler was substantially limited in the activity of working. Regarding the activity of working, EEOC regulations provide that "substantially limits" means "significantly restricted in the ability to perform either a class or broad range of jobs in various classes," and that the inability to perform a single particular job for one employer does not constitute a substantial limitation. The court found that Weiler was not substantially limited, as she could have worked for another employer, but could not work for Skorupka. Thus, the court held that she was not disabled under the ADA.
The district court also found that Weiler was not a "qualified individual" under the Act. Weiler testified that initially she was not able to work for Skorupka. However, she later admitted that she was unable to return to work at HFC in any position. Thus, because she could not work anywhere at HFC, she was not qualified to perform the essential duties of her position. The court added that even if Weiler had established the first two elements of a prima facie case, her claim would fail as HFC's actions toward her constituted reasonable accommodation. The court noted that HFC provided short-term leave, applied for long-term benefits, offered her counseling and the opportunity to post for another position. The court found these efforts to be reasonable accommodations, and granted HFC summary judgment.
Weiler v. Household Finance Corp., 1995 WL 452977 (N.D. Ill. 1995), aff'd 101 F.3d 519 (7th Cir. 1996).