The Seventh Circuit held that the record showed that: (1) the plaintiff experienced severe anxiety attack at workplace, during which she shouted at her co-workers and threatened to harm herself, which required the defendant to call ambulance; and (2) a physician report after the attack indicated that the plaintiff remained at risk for potentially violent behavior towards herself and others.
The plaintiff argued that the employer was making a "direct threat" defense, which it had not plead and which imposed the burden on the defendant to show a likelihood that the plaintiff would harm herself or others. However, the Seventh Circuit found that "direct threat" defense did not apply as the employee's behavior demonstrated that she was not qualified to perform her job. The fact that plaintiff's physician submitted a note indicating that the plaintiff could return to work at future date did not require different result.