Bodenstab v. County of Cook, No. 05 C 281 (N.D.Ill. Jan. 28, 2008)

The United States District Court for the Northern District of Illinois granted a hospital's motion for summary judgment in a physician's lawsuit based on the Americans with Disabilities Act ("ADA"). The physician allegedly made death threats regarding his former supervisor and other co-workers, then underwent evaluations which determined that he had a psychiatric disorder which could lead to compromised patient care. He was terminated by the hospital and filed suit under the ADA.

The court stated that the ADA does not require employers to take unnecessary risks when dealing with mentally or physically impaired employees, and found that the hospital's decision that the physician posed a direct threat was supported by the FBI and police investigation as well as independent medical opinions, and the physician failed to set forth sufficient evidence to support the contrary. The court also held, among other things, that the physician was not disabled because he did not have an impairment that substantially limited him in one or more major life activities.