Palmer v. Circuit Court of Cook County’s Empirical Analysis

Citation profile

46 federal appellate · 8 district · 11 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 114 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[I]f an employer fires an employee because of the employee’s unacceptable behavior, the fact that that behavior was precipitated by a mental illness does not present an issue under the Americans with Disabilities Act. The Act does not require an employer to retain a potentially violent employee. Such a requirement would place the employer on a razor’s edge — -in jeopardy of violating the Act if it fired such an employee, yet in jeopardy of being deemed negligent if it retained him and he hurt someone. The Act protects only “qualified” employees, that is, employees qualified to do the job for which they were hired; and threatening other employees disqualifies one. It is true that an employer has a statutory duty to make a “reasonable accommodation” to an employee’s disability, that is, an adjustment in working conditions to enable the employee to overcome his disability, if the employer can do this without “undue hardship.” 42 U.S.C. sec. 12112 (b)(5)(A). But we cannot believe that this duty runs in favor of employees who commit or threaten to commit violent acts. The retention of such an employee would cause justifiable anxiety to eoworkers and supervisors. It would be unreasonable to demand of the employer either that it force its employees to put up with this or that it station guards to prevent the mentally disturbed employee from getting out of hand.”

   12 later decisions quote this exact passage
   e.g. Mayo v. PCC Structurals, Inc. · Felix v. Wisconsin Department of Transportation

2. “There is no evidence [plaintiff] was fired because of her mental illness. She was fired because she threatened to kill another employee. The cause of the threat was ... her mental illness .... But if an employer fires an employee because of ... unacceptable behavior, the fact that that behavior was precipitated by a mental illness does not present an issue under the [ADA].”

   1 later decision quote this exact passage
   e.g. Scheidler v. Indiana

3. “a personality conflict with a supervisor or coworker does not establish a disability within the meaning of the disability law even if it produces anxiety and depression, as such conflicts often do. Such a conflict is not disabling; at most it requires the worker to get a new job.”

   1 later decision quote this exact passage
   e.g. 382 F. Supp. 3d 842 - Summers v. Target Corp.