Richardson v. Chicago Transit Authority

Mark Richardson (plaintiff) was a bus driver for the Chicago Transit Authority (CTA) (defendant). During his employment, Richardson went from a body weight of 350 lbs. to 566 lbs. Under the Body Mass Index (BMI), a measurement of obesity calculated from weight and height, Richardson was extremely obese. Richardson also suffered from hypertension. Richardson contracted the flu and took leave from work. Looking at Richardson’s full medical record, the CTA told Richardson that he could not return to work until his blood pressure was under control. Richardson eventually took a special assessment to determine whether he was able to drive the vehicles required by his job. The CTA employees running the assessment made jokes about Richardson’s weight during the process. The employees found that Richardson could drive the requisite vehicles but cited several safety concerns related to Richardson’s physical size and weight. The CTA’s manager of bus instruction recommended that Richardson not be permitted to drive CTA buses due to the assessment observations, bus-manufacturing requirements, and the limited space available in the driver’s area. The CTA terminated Richardson’s employment, and Richardson filed suit in federal district court, arguing that the CTA took adverse employment action against him due to his obesity in violation of the Americans with Disabilities Act (ADA). The district court granted summary judgment to the CTA, finding that Richardson was not disabled under the ADA. Richardson appealed to the Seventh Circuit.