Case Explained: MICHAEL JEZIOR v. CITY OF CHICAGO

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-06-24

The seventh-circuit affirmed the district court’s grant of summary judgment in favor of the City of Chicago on Michael Jezior’s Americans with Disabilities Act (ADA) claims for failure to accommodate and disability discrimination. The court held that Jezior was not a “qualified individual” for an in-place lieutenant promotion at O’Hare Airport because the essential functions of those specific positions required firefighting duties he could no longer perform, and the ADA does not require an employer to create a new job or strip existing roles of their principal duties to accommodate an employee. Furthermore, the court determined that Jezior’s requested accommodation was unreasonable because the employer is not obligated to provide an employee’s preferred accommodation, and Jezior voluntarily terminated the required “interactive process” by refusing to submit necessary medical paperwork to explore alternative positions in the Fire Prevention Bureau or other accommodations. Regarding the discrimination claim, the court found no genuine dispute of material fact regarding causation or pretext, noting that the City’s explanations for denying the promotion were consistent with its cost-cutting civilianization efforts and that Jezior failed to present valid comparators who received similar promotions without disability-related restrictions. Consequently, the judgment in favor of the City stands, and Jezior’s appeal is dismissed without further relief.

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