Psomas v. Chicago Transit Authority

CourtDistrict Court, N.D. Illinois
DecidedJuly 23, 2025
Docket1:24-cv-12173
StatusUnknown

This text of Psomas v. Chicago Transit Authority (Psomas v. Chicago Transit Authority) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Psomas v. Chicago Transit Authority, (N.D. Ill. 2025).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JIM PSOMAS, individually and on behalf ) of all others similarly situated ) ) No. 24 C 12173 Plaintiff, ) v. ) Chief Judge Virginia M. Kendall ) ) CHICAGO TRANSIT AUTHORITY ) ) Defendant. )

MEMORANDUM OPINION & ORDER Plaintiff Jim Psomas brings this class action lawsuit against Defendant Chicago Transit Authority (CTA), under the Americans with Disabilities Act (ADA), for disability-based discrimination relating to CTA’s COVID-19 vaccination policy. Psomas alleges three causes of action against CTA, all of which he brings on behalf of himself and a putative class: (I) failure to accommodate; (II) retaliation on the basis of disability; and (III) discrimination on the basis of a perceived disability. CTA’s moves to strike the putative class allegations and to dismiss Psomas’s individual claims for discrimination and retaliation. For the following reasons, the Court grants, in part, CTA’s Motion [19]. BACKGROUND This case concerns CTA’s treatment of employees who requested medical accommodations in response to CTA’s COVID-19 vaccination policy. (See generally Dkt. 1). The Complaint alleges that at the highest levels of the company, CTA willfully pre-determined that it would not perform individualized assessments of each unvaccinated employee’s specific circumstances to determine whether a reasonable accommodation option was available and instead, chose to terminate CTA employees entitled to an exemption. (Id. at ¶ 53). The policy led CTA to summarily deny at least 119 out of 120 employees’ requests for medical exemptions from complying with CTA’s COVID-19 vaccine policy. (Id. at ¶ 2). All of these employees were subsequently terminated “for-cause,” losing wages and other benefits. (Id. at ¶ 91).

The events allegedly unfolded as followed: On September 3, 2021, CTA announced that all of its employees would have to receive a COVID-19 vaccine. (Dkt. 1 ¶ 33). On September 13, 2021, at the direction of his doctor, Psomas requested an accommodation from the CTA Accommodation Review Committee so that he did not have to comply with the vaccine mandate because he has Hashimoto’s Disease. (Id. at ¶ 34). Hashimoto’s is an autoimmune disorder affecting the thyroid gland; the disease leads to symptoms such as pain, fatigue and sluggishness, goiter, joint pain, and weakness. (Id. at ¶ 22). Though CTA formally denied Psomas’s request with a letter, it functionally accommodated his request for the next several months. (Dkt. 23 at 2). CTA’s other unvaccinated employees were also given functional accommodations, which included CTA requiring such employees test once a week and provide proof of a negative COVID-19 test. (Id.)

Despite its ability to accommodate, Psomas claims that CTA determined that it would not permanently accommodate any putative class member, regardless of their essential duties, location, access to free or low cost COVID-19 testing, remote work status, ability to work remotely, and/or any individual circumstances. (Dkt. 23 at 4). On January 24, 2022, CTA revoked what had become a functional accommodation for Psomas. (Id.) CTA terminated Psomas on January 31, 2022. (Id. at ¶ 50). The same was true of the other allegedly disabled employees who had requested accommodation. CTA denied almost every request and demanded that each member of the putative class abandon his disability needs if he desired to preserve his career. (Id. at ¶ 46). Subsequently, all others in class were either terminated or forced to retire. (Id. at ¶ 51). CTA allegedly treated those terminations as “for-cause” resulting in extended periods of lost wages, lost 401(k) contributions, lost vacation time, and lost healthcare benefits. (Id. at ¶ 91). Psomas seeks damages, including back pay, front pay, liquidated damages, punitive

damages, lost benefits, compensatory damages, damages for emotional distress, pain and suffering, reasonable attorney’s fees and costs, declaratory relief, and injunctive relief. (Dkt. 1 ¶ 13). CTA moves to strike all of the class allegations and to dismiss Psomas’s individual claims for retaliation and discrimination based on a perceived disability. (Dkt. 19). LEGAL STANDARD To survive a motion to dismiss for failure to state a claim, the complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Kaminski v. Elite Staffing, 23 F.4th 774, 776 (7th Cir. 2022) (quoting Fed. R. Civ. P. 8(a)(2)). Specifically, “a plaintiff must allege ‘enough facts to state a claim that is plausible on its face.’” Allen v. Brown Advisory, LLC, 41 F.4th 843, 850 (7th Cir. 2022) (quoting Bell Atl. Corp. v. Twombly, 550 U.S.

544, 570 (2007)). A claim is facially plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). At the same time, “allegations in the form of legal conclusions are insufficient to survive a Rule 12(b)(6) motion.” McReynolds v. Merrill Lynch & Co., Inc., 694 F.3d 873, 885 (7th Cir. 2012) (citing Iqbal, 556 U.S. at 678). As such, “[t]hreadbare recitals of the elements of the cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678. Further, the moving party bears the burden of establishing the insufficiency of the plaintiff's allegations. Marcure v. Lynn, 992 F.3d 625, 631 (7th Cir. 2021). DISCUSSION CTA moves to strike Psomas’s three class allegations (i.e., failure to accommodate,

retaliation based on disability, and discrimination based on perceived disability) arguing that Psomas has failed to plead facts sufficient to support a Rule 23 class action. (Dkt. 20 at 4). Additionally, CTA moves to dismiss Psomas’s individual retaliation and discrimination based on perceived disability claims. (Dkt. 20 at 11–15). I. Motion to Strike a. Legal Standard Striking class allegations at the pleading stage is only appropriate “when [the allegations] are facially and inherently deficient . . . . ” See, e.g., Miles v. Am. Honda Mot. Co., Inc., 2017 WL 4742193, at *5 (N.D. Ill. Oct. 19, 2017) (quoting Cholly v. Uptain Group, Inc., 2015 WL 9315557, *3 (N.D. Ill. Dec. 22, 2015)); see also Huddleston v. Am. Airlines, Inc., 2018 WL 4742097, at *2

(N.D. Ill. Oct. 2, 2018). Federal Rule of Civil Procedure 23(a) requires a plaintiff class to satisfy the requirements of numerosity, commonality, typicality, and adequacy. Fed R. Civ. P. 23(a); see also Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 349 (2011). In identifying these factors, the rule requires: (1) the class is so numerous that joinder of all members is impracticable; (2) there are questions of law or fact common to the class; (2) the claims or defenses of the representative parties are typical of the claims or defenses of the class; and (4) the representative parties will fairly and adequately protect the interests of the class.

Fed R. Civ. P. 23(a).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Amchem Products, Inc. v. Windsor
521 U.S. 591 (Supreme Court, 1997)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Kotwica v. Rose Packing Co., Inc.
637 F.3d 744 (Seventh Circuit, 2011)
Wal-Mart Stores, Inc. v. Dukes
131 S. Ct. 2541 (Supreme Court, 2011)
Damasco v. Clearwire Corp.
662 F.3d 891 (Seventh Circuit, 2011)
Kenneth Harper v. C.R. England, Inc
687 F.3d 297 (Seventh Circuit, 2012)
George McReynolds v. Merrill Lynch
694 F.3d 873 (Seventh Circuit, 2012)
Arnold Chapman v. First Index, Incorporated
796 F.3d 783 (Seventh Circuit, 2015)
Ronald Shell v. Burlington Northern Santa Fe R
941 F.3d 331 (Seventh Circuit, 2019)
Brannen Marcure v. Tyler Lynn
992 F.3d 625 (Seventh Circuit, 2021)
Joanne Kaminski v. Elite Staffing, Inc.
23 F.4th 774 (Seventh Circuit, 2022)
Joseph Allen, IV v. Brown Advisory, LLC
41 F.4th 843 (Seventh Circuit, 2022)
Wright v. Mishawaka Housing Authority
225 F. Supp. 3d 752 (N.D. Indiana, 2016)
Koty v. Dupage Cnty.
900 F.3d 515 (Seventh Circuit, 2018)
Birchmeier v. Caribbean Cruise Line, Inc.
302 F.R.D. 240 (N.D. Illinois, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Psomas v. Chicago Transit Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/psomas-v-chicago-transit-authority-ilnd-2025.