Keisha Lewis v. Indiana Department of Transportation

── Keisha Lewis v. Indiana Department of Transportation ── Court: Court of Appeals for the Seventh Circuit Date: April 22, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 25-1776 KEISHA L. LEWIS, Plaintiff-Appellant, v. INDIANA DEPARTMENT OF TRANSPORTATION, Defendant-Appellee. ____________________ Appeal from the United States District Court for the Southern District of Indiana, Indianapolis Division. No. 1:23-cv-01865-JMS-MJD — Jane Magnus-Stinson, Judge. ____________________ ARGUED JANUARY 30, 2026 — DECIDED APRIL 22, 2026 ____________________ Before BRENNAN, Chief Judge, and ROVNER and HAMILTON, Circuit Judges. BRENNAN, Chief Judge. The Indiana Department of Transportation fired Keisha Lewis for poor performance and insubordination. Lewis, who suffers from a kidney condition, previously clashed with her supervisors about her remote- work accommodation, job responsibilities, and performance reviews. After her termination, Lewis sued the Department and certain individuals, alleging disability discrimination, 2 No. 25-1776 race discrimination, and retaliation in violation of the Reha- bilitation Act, Title VII, and 42 U.S.C. § 1981. After Lewis vol- untarily dismissed some counts, the district court granted summary judgment to the Department on those remaining. Because no reasonable jury could find for Lewis on any of her claims, we affirm. I Lewis worked for the Indiana Department of Transporta- tion in the Real Estate Division from December 2014 until her termination on December 20, 2022. Her responsibilities in- cluded reviewing and approving federal relocation claim vouchers for assistance payments. The claim process went as follows: consultants helped people displaced by highway projects find replacement housing or business locations. Then, the consultants submitted paperwork to the Real Estate Division, and Lewis would approve and mail checks to the displaced persons. Lewis’s problems with the Department began in 2021. That year, the Director of Real Estate, William Geibel, con- ducted a job justification review. Lewis received a promotion and a raise. But she complained to Geibel that her raise was insufficient. Lewis, a black employee, received a 9 percent raise, yet a white colleague received a 12 percent raise. Geibel testified that the State Personnel Department sets pay rates. Per Geibel, those rates pre-determined the raises available for each employee, depending on base salary. The other em- ployee’s base salary was lower than Lewis’s, so he received a higher percentage raise. Additional difficulties arose concerning Lewis’s remote- work accommodation. For context, in March 2020, the No. 25-1776 3 Department staff began working out of the office due to COVID-19. Although the employees returned to the office by summer 2022, Lewis received a remote-work accommodation for health issues related to her kidney transplant and compro- mised immune system. Her accommodation also allowed her to meet her supervisors outside the downtown office to drop off the processed checks. After Lewis began working from home—and contrary to the directions of her supervisor, Julie Foreman—Lewis stopped processing checks for the Finance Department. She also emailed the Finance Operations Man- ager and said she would no longer assist with the relocation vouchers. Around this time, it was recommended that Fore- man have daily virtual meetings with Lewis to monitor her work progress. Lewis’s supervisors soon stepped in. When Foreman found out that Lewis was refusing work, Foreman contacted Human Resources Director Janell Gurney. In her email, Fore- man reported Lewis’s refusal to assist with the vouchers and Lewis’s backl