An employer's refusal to reinstate an employee who quit during an alleged episode of depression does not violate the Americans with Disabilities Act (ADA). A United States District Court sitting in Illinois granted an employer's motion for summary judgment.

In 1986, Acme Steel Company hired Roscoe Wooten to work as a laborer. His job involved difficult work with heavy machinery. Wooten performed well and was eventually promoted. During this time, Wooten began to suffer from manic depression. As the depression worsened, Wooten sought help. Help came in the form of Acme's personnel department, which recommended him to a certified counselor. Wooten began therapy and Acme assisted Wooten in obtaining additional counseling and stress management. Despite the therapy, Wooten's depression worsened and during a severe depressive episode one Friday evening, he called his foreman and verbally resigned. The following Monday, Wooten called Acme to retract his resignation, but Acme refused to reinstate him.

Wooten sought help from the United Steel Worker's Union, which had Wooten reevaluated and determined to be depressed. The Union requested that Acme reinstate Wooten, but Acme again refused. Wooten filed an ADA action in federal court and Acme moved for summary judgment.

The District Court granted the motion, holding that Acme had not failed to reasonably accommodate a person with a disability as required by the ADA. Reinstating Wooten, the court held, would do nothing to reasonably accommodate him. Nor did Wooten point to any accommodation that would assist in managing his depression. The court also dismissed Wooten's disparate treatment claim because he failed to prove that he had been treated differently than non-disabled co-workers who had resigned and were later reinstated. He had merely made allegations to such an effect.