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Graham v. St. John's United Methodist Church

913 F. Supp. 2d 650 (2012)

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Graham v. St. John’s United Methodist Church

United States District Court for the Southern District of Illinois

913 F. Supp. 2d 650 (2012)

Facts

As a result of a serious beating, Richard Graham (plaintiff) suffered a permanent cognitive disability that rendered it difficult for him to articulate his thoughts, comprehend information, and challenge authority figures. Graham began working part-time as a custodian at St. John’s United Methodist Church (St. John’s) (defendant) in 2008. After the other part-time custodian left, Graham assumed all custodial duties and performed his work satisfactorily. Reverend Sheryl Palmer (defendant) expected Graham to work 35 to 40 hours per week but allowed him to put only 25 hours on his timesheets, and Palmer instructed Graham to perform her personal chores. Palmer called Graham “stupid” and “retard” and allowed other employees to do so. Palmer also yelled at Graham in front of other people to embarrass him. In 2011, two church members advocated for Graham by helping him file a complaint with the Illinois Department of Labor to investigate Palmer’s mistreatment and by informing Palmer and St. John’s that Graham was ill and scheduled for surgery. Palmer unilaterally scheduled Graham to return to work soon after his surgery and then terminated Graham because he was unable to return to work. Graham sued St. John’s and Palmer, alleging disability discrimination under the Americans with Disabilities Act (ADA). St. John’s moved to dismiss Graham’s case, claiming that Graham failed to prove that he has a disability under the ADA’s definition of disability.

Rule of Law

Issue

Holding and Reasoning (Reagan, J.)

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