Does Title II of the Americans with Disabilities Act apply to employment-related discrimination claims, even though Title I of the Act specifically addresses such claims? Answering this "question of first impression" in the circuit, in Brumfield v. City of Chicago, No. 11-2265 (Nov. 6, 2013), the Seventh Circuit today joined the Ninth and Tenth Circuits in concluding that Title II does not extend to employment-discrimination claims. Such claims must be brought under Title I. The court determined that because, read in context, Title II unambiguously does not reach employment-discrimination claims, the court need...
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