Plaintiffs may not bring discrimination claims under the federal Americans with Disabilities Act (“ADA”) unless the plaintiff’s disability is the “but for” cause of the challenged action, according to the Seventh Circuit Court of Appeals (covering Illinois, Indiana, and Wisconsin). See Serwatka v. Rockwell Automation, Inc. Causation in discrimination claims can take multiple forms; in mixed motive claims under federal Title VII, an employer may still be liable to an employee where an employee’s protected characteristic played a role in causing the challenged decision, even though the employer would have made the same decision regardless of the characteristic. Citing Gross v. FBL Financial Services (in which the court rejected mixed motive claims under the federal Age Discrimination in Employment Act, reported in the July 2009 FEB), the court determined the ADA, like the ADEA, lacks statutory support to allow mixed motive claims and reversed the plaintiff’s award.