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Gratzl v. Office of the Chief Judges of the 12th, 18th, 19th and 22nd Judicial Circuits

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ARGUED NOVEMBER 5, 2009

Before BAUER, MANION, and WILLIAMS, Circuit Judges.

Jeanne Gratzl suffers from incontinence and must get to a restroom within minutes of feeling an urge to urinate. She was hired by the Office of Chief Judges of the 12th, 18th, 19th and 22nd Judicial Circuits to work as a electronic court reporter specialist working exclusively in the control room of the DuPage County, Illinois courthouse. The job was ideal for her. Her responsibilities were so compatible with her medical condition that her supervisors were not even aware of it for five years. Unfortunately for Gratzl, this ideal situation changed in 2006 when, in response to a directive from the Illinois Coordinator of Court Reporting Services, the Chief Judge eliminated her specialist position and required all court reporters to rotate through live courtrooms as well as the control room. Believing that she was unable to perform in-court reporting due to her incontinence, Gratzl requested an accommodation. After several months, discussions broke down and, when she would not return to work, her employment was terminated. Gratzl brought this suit against her employer under the Americans with Disabilities Act (ADA), 42 U.S.C. § 12111 et seq. and the Rehabilitation Act, 29 U.S.C. § 794 et seq. The district court granted summary judgment to the defendant. We affirm.

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