Exhibit B

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Troutman Sanders LLP 

227 West Monroe, Suite 3900 

Chicago, IL 60606 

troutman.com 

Misha Tseytlin 

(312) 759-5947 

misha.tseytlin@troutman.com 

Sean T.H. Dutton 

(312) 759-1937

sean.dutton@troutman.com 

June 17, 2020 

VIA EMAIL AND OVERNIGHT MAIL 

J.B. Pritzker 

Governor of the State of Illinois 

Office of the Governor 

100 W. Randolph, 16-100 

Chicago, IL 60601 

Grace B. Hou 

Secretary, Illinois Department of Human Services 

401 South Clinton St., Seventh Floor 

Chicago, IL 60607 

Re: The State of Illinois’ Unconstitutional and Unlawful Shuttering of Community Day 

Services Providers 

Dear Governor Pritzker and Secretary Hou: 

We write on behalf of John “Chris” McDonald regarding your unlawful decision to shutter 

Community Day Services (“CDS”) providers statewide through (at least) August 31, 2020. 

This indefinite elimination of these programs, thereby depriving disabled individuals like 

Mr. McDonald of the services that they so desperately need, has no COVID-19-related 

justification, especially when compared to the State’s ongoing treatment of facilities and services 

for able-bodied persons. Although the Governor has claimed that his administration makes its 

COVID-19 decisions by “rely[ing] upon the data, rely[ing] upon the science, and rely[ing] upon 

the experts,”1 that claim is patently false in this instance. The Centers for Disease Control and 

Prevention (“CDC”) has determined that disabled persons “are not inherently at higher risk for 

1

 Kristen Thometz, WTTW, Pritzker Says Illinois on Track to Move to Phase 4, Won’t Lift 

Restrictions Early (June 10, 2020), https://news.wttw.com/2020/06/10/pritzker-says-illinois-ontrack-move-phase-4. 

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Governor J.B. Pritzker 

June 17, 2020 

Page 2

becoming infected with or having severe illness from COVID-19.”2 And the State has given no 

reason whatsoever—let alone a reason grounded in data, science, and experts—for excluding CDS 

programs from the Governor’s “Restore Illinois” Plan to reopen. This discriminatory shuttering 

is so obviously unjustified by any concerns related to COVID-19 that it can only be explained as 

a bad-faith effort to use this crisis as cover for reducing and changing fundamentally the services 

that the State of Illinois will provide to disabled individuals. 

The actions here are obviously illegal. In shuttering CDS programs for no reason other 

than the disabled status of its participants, contrary to the State’s treatment of similar businesses 

and programs for non-disabled persons, the State has discriminated against Mr. McDonald and 

other disabled individuals, in violation of the Rehabilitation Act and the Americans with 

Disabilities Act. Moreover, these actions are based on an impermissible attitude toward disabled 

persons, contrary to the Equal Protection Clause of the Fourteenth Amendment and the Supreme 

Court’s decision in City of Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432 (1985). 

In light of these clear and obvious legal defects, we demand that Mr. McDonald be able 

to attend his CDS program starting on Monday, June 22, and require a response to this letter 

by no later Friday, June 19, informing Mr. McDonald that he can promptly return to his 

program. Every day that Mr. McDonald is unable to attend his CDS program imposes serious and 

unjustified emotional and physical suffering, caused by your unlawful actions. 

Absent immediate corrective action, we intend to file a federal lawsuit next week, seeking 

emergency injunctive relief against your unlawful policy, a permanent injunction ensuring that 

you will no longer be able to indiscriminately shutter CDS programs in this way again, and 

damages for all of those harmed by your policy. In addition, we will inform the United States 

Department of Justice of your ongoing disregard of the federal statutory and constitutional rights 

of disabled individuals so that the Department can also consider taking appropriate actions against 

your illegal conduct. 

I. The COVID-19 Pandemic And DHS’s Discriminatory Treatment Of Disabled 

Individuals Like Mr. McDonald 

A. The COVID-19 Outbreak In Illinois And The Governor’s Response 

On March 9, 2020, Governor Pritzker announced a state of emergency for the entire State 

of Illinois,3 and, through mid-March, prohibited public gatherings, closed bars and restaurants to 

2

 CDC, Coronavirus Disease 2019 (COVID-19): People with Disabilities (Apr. 7, 2020), 

https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-with-disabilities 

.html. 

3

 Gubernatorial Disaster Proclamation (Mar. 9, 2020), available at https://www2.illinois.gov/ 

sites/gov/Documents/CoronavirusDisasterProc-3-12-2020.pdf. 

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Governor J.B. Pritzker 

June 17, 2020 

Page 3

in-person dining, closed schools and nonessential businesses, and entered a statewide stay-at-home 

order for all citizens not performing essential functions.4 The Governor deemed these measures 

necessary to stop the rapid spread of this virus, especially among our most vulnerable populations.5 

After the State began to successfully “flatten the curve” on COVID-19 transmissions, the 

Governor announced his “Restore Illinois” plan to safely re-open the State and restart the 

economy.6 Currently in “Phase 3 – Recovery” of the Plan, non-essential manufacturing and other 

non-essential businesses are permitted to reopen with social distancing, personal protective 

equipment, and adequate sanitization practices. Furthermore, both outdoor recreation and nonovernight day camps for children may re-open under “Phase 3” of the plan, as long as adequate 

safety measures are in place.7 Upon entering “Phase 4 – Revitalization”—which can begin as soon 

as June 26,8 with all four regions currently on pace to meet the metrics necessary to do so9—all 

manufacturing, non-essential businesses, outdoor recreation, bars and restaurants, health and 

fitness clubs, and movie theaters can open with approved safety guidance, and public gatherings 

of 50 or fewer people can resume.10

B. CDS Programs And The State’s Unlawful Closure Of All Such Operations 

Through—At Minimum—August 31. 

CDS programs provide developmentally disabled adults assistance in gaining and 

improving “self-help, socialization[,] and adaptive skills in a non-residential setting,” including 

4 See, e.g., Executive Order 2020-10 (Mar. 20, 2020), available at https://www2.illinois.gov/ 

Pages/Executive-Orders/ExecutiveOrder2020-10.aspx. 

5

Id. 

6 See Office of the Governor, Restore Illinois: A Public Health Approach to Safely Reopen Our 

State (May 5, 2020), available at https://coronavirus.illinois.gov/sfc/servlet.shepherd/document 

/download/069t000000BadS0AAJ?operationContext=S1. 

7 See Ill. Dep’t of Commerce, Day Camps Guidelines (May 24, 2020), available at https://dceo 

covid19resources.com/assets/Restore-Illinois/businessguidelines3/summerprograms.pdf. 

8

 Thometz, Pritzker Says Illinois on Track to Move to Phase 4, Won’t Lift Restrictions Early, 

supra. 

9

 Chad Yoder, et al., Chicago Tribune, When Can Illinois Move to Phase 4 of Reopening Plan? 

Here’s Where Each Region Stands (June 14, 2020), available at https://www.chicagotribune.com 

/coronavirus/ct-viz-region-status-reopen-illinois-plan-20200520-crs7jzzejng67c2supwcn2trkmhtmlstory.html. 

10 See Restore Illinois, supra. 

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training on “[q]uantitative skills” and “[e]nhancement of productive work activities.”11 These 

programs offer both skills training and job coaching to help developmentally disabled individuals 

succeed in the workplace.12 Notably, while the CDC has explained that COVID-19 poses a higher 

risk of death and serious illness among the elderly13 and persons with underlying chronic medical 

conditions,14 the CDC has found no similar elevated risks among the disabled.15 

Under the Governor’s early shutdown measures, and beginning on March 17, the Illinois 

Department of Human Services (“DHS”) shuttered CDS programs, barring any of the disabled 

workers from returning to work.16 Disabled workers were paid through March 17, but have not 

received any work or payment since, with the exception of some lingering checks related to preshutdown work. DHS’s COVID-19 guidance for CDS providers states that they may no longer 

provide their services to disabled workers, but that “CDS funds will be used to pay staff salaries” 

in the interim,17 and DHS has continued to receive federal funding “to provide services to . . . 

persons with disabilities who are disproportionately affected by the ongoing COVID-19 

pandemic.”18 Furthermore, DHS has recently issued a guidance letter stating that the prohibition 

of CDS program operations will extend to at least August 31, 2020, to be “consistent with the 

Illinois Department of Aging and their decision to keep Adult Day Sites closed through 

11 See DHS, Community Day Services, https://www.dhs.state.il.us/page.aspx?item=48074. 

12 See DHS, Developmental Disability, https://www.dhs.state.il.us/page.aspx?item=32253. 

13 See CDC, Coronavirus Disease 2019 (COVID-19): Older Adults (Apr. 30, 2020), 

https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/older-adults.html. 

14 See CDC, Coronavirus Disease 2019 (COVID-19): Clinical Questions about COVID-19: 

Questions and Answers (June 4, 2020), https://www.cdc.gov/coronavirus/2019-

ncov/hcp/faq.html#Transmission. 

15 See CDC, Coronavirus Disease 2019 (COVID-19): People with Disabilities, supra (“Most 

people with disabilities are not inherently at higher risk for becoming infected with or having 

severe illness from COVID-19.”). 

16 See DHS, UPDATED – COVID 19 Community Day Services (CDS) & Residential Rates and 

Reimbursement, https://www.dhs.state.il.us/page.aspx?item=123490. 

17 Id.

18 Victoria Idoni, WSILTV.com, Keeping Seniors Connected in Illinois (May 29, 2020), 

https://wsiltv.com/2020/05/29/keeping-seniors-connected-in-illinois/. 

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Governor J.B. Pritzker 

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August 31.”19 This decision was made without contacting all CDS programs to determine their 

ability to operate safely with precautions in light of COVID-19. Critically, the State gave no 

justification whatsoever for excluding CDS programs from the “Restore Illinois” Plan, while at 

the same time permitting similar businesses and programs to open under “Phase 3,” provided that 

they adopt reasonable safety precautions. And the State has offered no explanation why CDS 

programs cannot reopen under the even-more-permissive Phase 4.

C. The Damaging Effects Of The State’s Decision On Mr. McDonald 

Mr. McDonald is a 46-year-old man with the intellectual capacity of a 5 year old. Before 

the COVID-19 pandemic, he was a regular participant in a CDS program in Peoria called 

“Community Workshop and Training Center” (“CWTC”), 20 which he attended on weekdays. 

CWTC has been in operation for over 60 years,21 and pays intellectually and developmentally 

disabled workers (whom they refer to as “consumers”) to do certain jobs and be productive in their 

community—in Mr. McDonald’s case, individually packaging construction hardware like nuts and 

bolts—while also providing attendant care and supervision to the disabled individuals. CWTC has 

maintained long-term contracts with essential private firms, employing roughly 170 consumers to 

process and package.22 This makes CWTC an essential business, so it has continued providing its 

packaging services even during the COVID-19 shutdown of CDS programs, although the work 

was completed through the efforts of its non-disabled employees who have replaced CWTC’s 

disabled consumers for the time being. In addition to revenue CWTC receives from these 

contracts, it also receives grant funding to support its operations.23 

CWTC is a superior provider of CDS programming, and its consumers get personal 

satisfaction and a sense of purpose from their work. In addition to work programming, CWTC 

19 Allison Stark, Director, Division of Developmental Disabilities, Letter to Providers (June 9, 

2020). 

20 See CWTC, https://www.cwtc.org/. 

21 CWTC, CWTC Promotes 60th Anniversary on TV!, https://www.cwtc.org/cwtc-promotes60th-anniversary-on-tv/. 

22 See CWTC, Organizational Employment, https://www.cwtc.org/organizational-employment/. 

23 See CWTC, Annual Report 2019 at 2, available at https://www.cwtc.org/wp-content/ 

uploads/2019/10/2019-Annual-Report.pdf. 

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Governor J.B. Pritzker 

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offers its consumers community programming, such as an art show, 24 annual awards dinner,25 and 

more. CWTC has developed a plan to safely return to pre-COVID-19 operations, including 

reducing consumers’ hours so that there are never more than 50 consumers in the building at one 

time, maintaining appropriate distancing, instituting increased sanitation measures, and suggesting 

transportation modifications so fewer consumers take public transportation to the center. 

Despite these principled and extensive plans for re-opening, DHS’ discriminatory decision 

orders CWTC and all other CDS providers closed through August 31, with devastating effects on 

those who most require DHS’ assistance, including Mr. McDonald. In particular, Mr. McDonald’s 

mental health has declined as a result of the State’s shuttering of CWTC, necessitating an increase 

in his anti-depressant and anti-anxiety medications. He has broken down in tears and asked his 

caretaker-sister if he still worked at his job or when he could get back to work. Even beyond these 

grave emotional and mental harms inflicted on disabled consumers like Mr. McDonald, consumers 

are currently unable to earn any income. All of these problems will continue and will exacerbate 

the harms disabled citizens currently suffer, to disastrous results, unless the State promptly acts to 

reverse their discriminatory treatment. 

II. The State’s Denial of Services Violates Disabled Individuals’ Constitutional and 

Statutory Rights

A. The Right To Be Free From Discrimination On The Basis Of Disability Under 

The Rehabilitation Act And The Americans With Disabilities Act

Congress has found that “individuals with disabilities continually encounter various forms 

of discrimination, including outright intentional exclusion, . . . overprotective rules and policies, 

. . . and relegation to lesser services, programs, activities, benefits, jobs, and other opportunities.” 

42 U.S.C. § 12101(a)(5). Thus, Congress “invoke[d] the sweep of congressional authority” and 

sought “to provide a clear and comprehensive national mandate for the elimination of 

discrimination against individuals with disabilities.” Id. § 12101(b)(1), (4). To that end, federal 

law now provides disabled Americans with broad protections from discrimination “in three major 

areas of public life”: the workplace; public services, programs, and activities; and public 

accommodations. Tennessee v. Lane, 541 U.S. 509, 516–17 (2004). Central to Congress’ goals 

related to disabled individuals are the Rehabilitation Act and the Americans with Disabilities Act 

(“ADA”). 

Under Section 504 of the Rehabilitation Act, “[n]o otherwise qualified individual with a 

disability . . . shall, solely by reason of her or his disability, be excluded from the participation in, 

be denied the benefits of, or be subjected to discrimination under any program or activity receiving 

24 See CWTC, Inspiring Abilities Virtual Art Show, https://www.cwtc.org/test/. 

25 See The CWTC Insider, Iss. 52 at 2 (Aug. 2019), available at https://www.cwtc.org/wpcontent/uploads/2019/10/August-2019-Newsletter.pdf. 

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Governor J.B. Pritzker 

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Federal financial assistance.” 29 U.S.C. § 794(a). A claim under this Section requires proof of 

four elements: “(1) the plaintiff must be a handicapped individual as defined by the Act; (2) the 

plaintiff must be ‘otherwise qualified’ for participation in the program; (3) the program must 

receive federal financial assistance; and (4) the plaintiff must have been denied the benefits of the 

program solely because of his handicap.” Reed v. Columbia St. Mary’s Hosp., 915 F.3d 473, 484 

(7th Cir. 2019) (citations omitted). Proving federal assistance merely requires a showing that “the 

relevant state agency . . . accept[s] federal funds, which all states do.” Wagoner v. Lemmon, 778 

F.3d 586, 592 (7th Cir. 2015). And “blanket exclusions” of disabled persons from programs are 

generally unacceptable. Knapp v. Nw. Univ., 101 F.3d 473, 483 (7th Cir. 1996). 

Similarly, Title II of the ADA prohibits a public entity from excluding a disabled individual 

“from participation in,” or denying them the benefits of, any “services, programs, or activities of 

[the] public entity.” 42 U.S.C. § 12132. To succeed on a claim under Title II of the ADA, which 

is “functionally identical” to a claim under the Rehabilitation Act, Wagoner, 778 F.3d at 592, a 

plaintiff must prove three elements. First, the plaintiff must show that he “is a qualified individual 

with a disability,” 42 U.S.C. § 12131(2), which, “in turn,” requires him to prove that he may 

“participat[e]” in a state “program[ ] with or without reasonable accommodations,” Love v. 

Westville Corr. Ctr., 103 F.3d 558, 560 (7th Cir. 1996). Second, the plaintiff must prove that he 

was “denied the benefits of the services, programs, or activities of a public entity or otherwise 

subjected to discrimination by such an entity.” Wagoner, 778 F.3d at 592 (citations omitted). And 

third, the plaintiff must demonstrate that “the denial or discrimination was by reason of his 

disability,” id., which includes claims of mixed-motive discrimination. See Reed, 915 F.3d at 484. 

Discriminatory intent is not required, and even a failure to provide a reasonable accommodation 

suffices to support a claim under the ADA. Washington v. Ind. High Sch. Athletic Ass’n, Inc., 181 

F.3d 840, 846–47 (7th Cir. 1999). Furthermore, Title II of the ADA authorizes an award of 

compensatory damages against public entities, United States v. Georgia, 546 U.S. 151, 154 (2006), 

upon a showing of “deliberate indifference.” Lacy v. Cook Cty., 897 F.3d 847, 857, 863 (7th Cir. 

2018). Deliberate indifference requires “(1) knowledge that a harm to a federally protected right 

is substantially likely, and (2) a failure to act upon that likelihood.” Id. (citation omitted). 

The State’s decision to shutter CDS programs like CWTC has unlawfully denied disabled 

citizens like Mr. McDonald the benefits and services of this public program. Mr. McDonald is a 

disabled individual who is otherwise qualified to participate in CDS programs—indeed, he has 

been an active and successful participant in these programs for over 20 years. This denial is plainly 

based on his disability, as evidenced both by the fact that the State has authorized similar 

businesses and programs for the non-disabled—such as manufacturing businesses and nonovernight day camps for children—to resume operations with basic safety measures in place, see 

supra p. 3, and that DHS has explicitly authorized state funds for the operation of CDS programs 

to continue to be used to pay the salaries of their non-disabled employees, see supra pp. 4–5. See

Reed, 915 F.3d at 484; Wagoner, 778 F.3d at 592. Nor is this a situation in which a disabled citizen 

seeks a modification that would fundamentally alter the nature of the service, program, or activity. 

See P.F. by A.F. v. Taylor, 914 F.3d 467, 472 (7th Cir. 2019). To the contrary, disabled citizens 

like Mr. McDonald would simply be required to abide by the very same social distancing, personal 

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Page 8

protective equipment, and adequate sanitization guidelines governing non-disabled participants in 

similar businesses and programs that have been, or soon will be, permitted to reopen. 

Further, rather than treat the disabled consumers of CDS services like these similar groups, 

the State has instead lumped them in with the elderly, and tie-barred access to CDS services with 

re-opening of services by the Illinois Department of the Aging.26 But the risks of COVID-19 to 

the elderly and the disabled are wholly dissimilar, with the disabled facing no greater risk of 

COVID-19 than the general population.27 See Knapp, 101 F.3d at 485–86 (observing that the 

Rehabilitation Act “prohibits authorities from deciding without significant medical support that 

certain activities are too risky for a disabled person” and that “[d]ecisions of this sort cannot rest 

on paternalistic concerns”). The State has offered no reasoned basis for excluding CDS programs 

from the “Restore Illinois” plan. Given that DHS and the Governor are certainly aware that 

disabled citizens like Mr. McDonald have been unlawfully denied these benefits, your decisions 

here constitute deliberate indifference of federally protected rights. Lacy, 897 F.3d at 863. 

B. The Right to Equal Protection of the Laws 

The Equal Protection Clause of the Fourteenth Amendment provides that “[n]o State shall 

. . . deny to any person within its jurisdiction the equal protection of the laws.” U.S. Const. amend. 

XIV, § 1. This Clause’s “command” is that “all persons similarly situated should be treated alike.” 

Lane, 541 U.S. at 522 (quoting Cleburne, 473 U.S. at 439). Laws that differentiate on the basis of 

intellectual or developmental disability are generally subject to “rational-basis review,” which 

requires the State to have a “rational relationship between the disparity of treatment and some 

legitimate governmental purpose.” Bd. of Trustees of Univ. of Ala. v. Garrett, 531 U.S. 356, 366–

67 (2001). But even under this relatively deferential standard of review, the intellectually and 

developmentally disabled are not left “entirely unprotected from invidious discrimination,” and a 

“State may not rely on a classification whose relationship to an asserted goal is so attenuated as to 

render the distinction arbitrary or irrational.” Cleburne, 473 U.S. at 446. Therefore, even though 

in many instances “the mentally [disabled] as a group are indeed different from others not sharing 

their misfortune,” when “this difference is largely irrelevant” it may not serve as a rational basis 

for distinguishing the disabled from others unless treating them identically “would threaten 

legitimate interests of the [State].” Id. at 448. Any alternative rule would impermissibly allow 

discrimination that “rest[s] on an irrational prejudice against the mentally [disabled].” Id. at 450. 

Here, the State’s decision to prohibit the continued operation of CDS programs and their 

benefits for the intellectually and developmentally disabled for the foreseeable future has harmed 

citizens like Mr. McDonald. Withholding these benefits from the intellectually and 

developmentally disabled would similarly seem to be based on “irrational prejudice against” them, 

26 See Stark, Letter to Providers, supra. 

27 CDC, Coronavirus Disease 2019 (COVID-19): People with Disabilities, supra; CDC, 

Coronavirus Disease 2019 (COVID-19): Older Adults, supra. 

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Page 9

id., and is actually harming those it claims to be protecting. Again, the intellectually and 

developmentally disabled do not face elevated risks as a group.28 Manufacturing employees and 

youth attendees of day camps are “most like” the disabled consumers of CDS programs, meaning 

they are the relevant comparators for treatment. Elim Romanian Pentecostal Church v. Pritzker, 

___ F.3d ___, 2020 WL 3249062, at *5 (7th Cir. June 16, 2020). Treating the disabled differently 

than these manufacturing employees and youth attendees of day camps, both of which the State is 

allowing to return to their respective activities with certain precautions, is based on nothing more 

than irrational prejudice. There is no legitimate, let alone rational, basis to distinguish the 

intellectually and developmentally disabled from the general population in the context of COVID19-related restrictions, and doing so in this instance violates the Equal Protection Clause’s 

“command” that “all persons similarly situated should be treated alike.” Lane, 541 U.S. at 522. 

* * * 

We demand that you lift immediately the prohibition on CDS operations, allowing disabled 

citizens like Mr. McDonald to have the same opportunities as everyone else to work and seek care, 

while complying with generally applicable public-health guidelines. Absent such immediate 

corrective action—including informing Mr. McDonald that he can return to his CDS program by 

no later than Monday, June 22—we will be forced to undertake legal process to protect the rights 

of our client and similarly situated disabled individuals across the State, and will inform the United 

States Department of Justice of your ongoing unlawful discrimination. 

Sincerely, 

MISHA TSEYTLIN

SEAN T.H. DUTTON

TROUTMAN SANDERS LLP 

227 W. Monroe Street 

Suite 3900 

Chicago, IL 60606 

(312) 759-5947 

(312) 759-1939 (fax) 

misha.tseytlin@troutman.com 

sean.dutton@troutman.com 

28 See CDC, Coronavirus Disease 2019 (COVID-19): Older Adults, supra; CDC, Coronavirus 

Disease 2019 (COVID-19): People with Disabilities, supra (“Most people with disabilities are not 

inherently at higher risk for becoming infected with or having severe illness from COVID-19.”). 

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