United States District Court, N.D. Illinois, Eastern Division
MEMORANDUM OPINION AND ORDER
S. SHAH UNITED STATES DISTRICT JUDGE.
Sandefur was a corrections officer enrolled in the Cook
County Sheriff’s Office’s Police Training
Academy. Defendants dismissed him from the academy, saying
that he lied about a disability parking placard. Sandefur
brings suit against Cook County and Sheriff Thomas Dart,
alleging violations of the Americans with Disabilities Act,
42 U.S.C. § 12112(a), and the Age Discrimination in
Employment Act, 29 U.S.C. § 623(a), as well as claims
under 42 U.S.C. § 1983 for violations of his rights to
due process and equal protection. Defendants move for summary
judgment. For the reasons below, the motion is granted.
judgment is appropriate if defendants show that there is no
genuine dispute as to any material fact and that they are
entitled to judgment as a matter of law. Fed. R. Civ. P.
56(a). There is a genuine dispute over a material fact if
“the evidence is such that a reasonable jury could
return a verdict for the nonmoving party.” Anderson
v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). As the
movants, defendants bear the burden of establishing that the
summary judgment standard is met, but Sandefur must show
evidence to establish every element of his claim for which he
will bear the burden of proof at trial. See Celotex Corp.
v. Catrett, 477 U.S. 317, 322–23 (1986). I
construe the facts in the light most favorable to Sandefur
and draw reasonable inferences from them in his favor.
Laborers’ Pension Fund v. W.R. Weis Co., Inc.,
879 F.3d 760, 766 (7th Cir. 2018).
is a deputy sheriff sergeant in the Cook County Department of
Corrections.  ¶ 11. He has disk desiccation in his
back and osteoarthritis in his knees, which cause him
intermittent pain for weeks at a time.  ¶¶
3–4. When the conditions flare up, Sandefur suffers
severe pain that affects his ability to walk short distances
and weakness that requires him to exert effort to remain
ambulatory, and he occasionally uses a cane.  ¶ 22;
 ¶ 5. Sometimes sitting and lying down is painful
for him too.  ¶ 7. Sandefur applied for and received
a disability parking placard because of his knee condition,
and he usually displayed the placard when parked at work.
 ¶ 29;  ¶¶ 8–9. Sandefur’s
wife had a placard too, but she and Sandefur never used each
other’s.  ¶¶ 24–25, 27.
was chosen to be a recruit for the Police Training Academy.
 ¶ 31. His doctor had signed a medical release for
him to participate in the academy’s POWER test-a
physical ability test that involved running and
weightlifting.  ¶ 69;  ¶ 22. On the first
day of the academy, instructors conducted an inspection of
the recruits’ vehicles, equipment, and attire. 
¶ 36. That day, Sandefur had a disability parking
placard hanging in his car.  ¶ 35. Investigator
Lange asked Sandefur why he had the placard, and Sandefur
responded that “it was there for his wife.” 
¶ 12. Investigator Lange yelled at Sandefur, telling him
that was illegal, and Sandefur said that he had forgotten to
take it down.  ¶ 12. Investigator Lange exclaimed to
the surrounding group-“can you believe this, now
they’re sending handicapped motherfuckers to the
academy.”  ¶ 12. Sandefur explained that when
he said the placard was “there for his wife,” he
meant that he had put it up for his wife’s benefit
because he and his wife had gone somewhere in his car the
night before.  ¶ 13. Then another officer-Sergeant
Cammack-walked over to Sandefur and saw the disability
placard.  ¶ 38. Sergeant Cammack asked Sandefur if
the placard was his, and Sandefur replied that it was his
wife’s.  ¶ 40.
Cammack reported news of the placard up the chain to
Lieutenant Camer and suggested that they consider whether
Sandefur had any limitations, considering the physical
training on the schedule for the day.  ¶ 20.
Lieutenant Camer contacted the Chief of the Human Resources
Division to see if Sandefur had filed anything regarding
special accommodations.  ¶ 43. The HR Chief said
that if Sandefur was medically cleared and not asking for any
special accommodations, there wouldn’t be any issues
with his employment.  ¶ 21. Sandefur submitted a
memorandum to Sergeant Cammack explaining that the parking
placard was approved by his doctor for an arthritic knee
condition and that he was not requesting any accommodations.
 ¶ 23. That same day, Lieutenant Camer and Sergeant
Cammack met with Sandefur, and Lieutenant Camer either asked
or ordered Sandefur to sign a HIPAA release form.  ¶
46. They told him that the release allowed them to have
specific information about his medical conditions in case he
got hurt.  ¶ 25. Defendants used the HIPAA release
to investigate Sandefur’s disability parking placard.
 ¶ 28.
next day, Deputy Inspector Goldsmith requested information
about Sandefur’s placard from the Secretary of State.
 ¶ 29. He later contacted someone from that office
and expressed a concern that Sandefur had been issued a
disability parking placard despite having submitted medical
waivers that allowed him to perform as a recruit in the
academy.  ¶ 58. The person he spoke to said they
would conduct an investigation and contact the approving
physician for an explanation.  ¶ 59.
weeks later, a management inquiry was opened to investigate
whether any misconduct had occurred.  ¶ 32. Sergeant
Sullivan was assigned to the inquiry.  ¶ 55; 
¶ 36. During his investigation, Sergeant Sullivan
received confirmation that Sandefur’s doctor had signed
the application he submitted for the parking placard. 
¶ 37. In the meantime, Sandefur continued participating
in the academy. Some of his instructors referred to his age
and called him “Pops” or “Old Timer.”
 ¶ 38. Investigator Lange also once said,
“it’s alright, he’s handicapped, you
know.”  ¶ 40.
Sergeant Sullivan concluded his investigation and determined
that Sandefur had made multiple inconsistent statements and
violated policies.  ¶¶ 56–57. He
recommended that “the allegation … that Police
Recruit Brad Sandefur was untruthful when applying for a
State of Illinois Handicap Placard be sustained,” 
¶ 41, and that Sandefur be removed from the academy and
sent back to his previous assignment.  ¶ 56. And so
just shy of his graduation from the academy, Sandefur was
reassigned back to the Department of Corrections  ¶
59;  ¶¶ 43; 56.
later applied for other opportunities within the department-
including a “C.O. to P.O.” class, promotions to a
police officer position and an electronic monitoring sergeant
position-but was denied because of disciplinary violations.
 ¶¶ 46–47, 49–51
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