Case Explained: MARIA DIFRANCO, as the Independent Administrator of the ESTATE OF MARCO DIFRANCO v. CITY OF CHICAGO, a municipal corporation

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-07 The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the City of Chicago, holding that the Estate failed to present sufficient evidence to create a genuine dispute of material fact regarding the City’s liability under the Americans with Disabilities Act (ADA), the Illinois Human Rights Act, and the Illinois Wrongful Death Act. The court applied the standard for failure-to-accommodate claims, requiring proof that the employer was aware of the disability and failed to provide a reasonable accommodation. The court reasoned that while the City’s documentation of the accommodation process was irregular and some documents appeared backdated due to the chaotic nature of the pandemic response, undisputed testimony established that Marco DiFranco was reassigned on March 23, 2020, to monitor public infrastructure from his individual police vehicle, thereby isolating him from others. The court held that procedural deviations did not negate the fact that DiFranco received a reasonable accommodation. Furthermore, regarding causation, the court noted that the Estate conceded the accuracy of the City’s exposure report, which indicated DiFranco was exposed to Covid-19 on or before March 19, prior to his request for reassignment. Because the Estate presented no evidence that DiFranco contracted the virus from a workplace exposure occurring after his accommodation request, it could not establish that any delay in accommodation proximately caused his death under the Wrongful Death Act. The practical consequence is that the judgment in favor of the City stands, and the Estate’s claims for damages are dismissed without trial. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.