A recent court ruling has upheld a decision in favor of a state transportation department, denying claims of discrimination under the Americans with Disabilities Act (ADA). On June 14, 2024, the Appellate Court of Illinois affirmed the judgment of the Circuit Court of Cook County in favor of the Illinois Department of Transportation (IDOT), dismissing allegations brought by William Macklin.
William Macklin, who has been employed by IDOT since 2011 as a highway maintainer lead worker, filed his complaint in May 2020. The case revolves around an incident that began on October 11, 2019, when Macklin suffered a stroke that affected his ability to swallow but left him otherwise physically capable. Despite feeling ready to return to work by mid-January 2020 and receiving clearance from his primary care physician, Macklin was placed on administrative leave due to federal guidelines requiring CDL holders who have had a stroke to remain off work for one year.
Macklin’s lawsuit claimed that IDOT discriminated against him by placing him on administrative leave from January 30, 2020, to October 28, 2020. He argued that this action violated the ADA because he was regarded as having a disability. At trial, Macklin testified about his job responsibilities and emphasized that he did not drive commercial motor vehicles despite holding a CDL. However, the jury found against Macklin, answering "no" to whether IDOT regarded him as having a disability under the ADA.
In his appeal, Macklin contended that the circuit court erred in denying his motion for judgment notwithstanding the verdict (n.o.v.) and abused its discretion in denying his motion for a new trial. He argued that the evidence overwhelmingly favored him and that IDOT’s actions were based on an incorrect interpretation of federal guidelines rather than any actual impairment he had. However, the appellate court held that there was sufficient evidence for the jury's verdict and noted that conflicting testimonies regarding whether IDOT employees believed Macklin had a disability justified upholding the original decision.
Macklin sought relief including judgment n.o.v., which would overturn the jury's verdict in his favor or alternatively requested a new trial based on claims that the jury's decision was against the manifest weight of evidence. The appellate court found no merit in these arguments and affirmed the lower court’s ruling.
The case was presided over by Honorable Patrick J. Sherlock at Cook County Circuit Court with Justices Mitchell, Lyle, and Navarro concurring in judgment at the appellate level. The case is identified as No. 1-23-0284.