Karmen Williams v. Tangoe Us, Inc.

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted July 14, 2026*
Decided July 15, 2026
Before
MICHAEL B. BRENNAN, Chief Judge
KENNETH F. RIPPLE, Circuit Judge
JOSHUA P. KOLAR, Circuit Judge
No. 25-2968
KARMEN WILLIAMS,
Plaintiff-Appellant,
v.
TANGOE US, INC.,
Defendant-Appellee.
Appeal from the United States District
Court for the Northern District of Illinois,
Eastern Division.
No. 24-cv-06669
Mary M. Rowland,
Judge.
O R D E R
Karmen Williams appeals the dismissal of her employment-discrimination suit
as a sanction for failure to comply with court orders. See FED. R. C IV. P. 37(b), 41(b). We
see no abuse of discretion in the court’s ruling and affirm.
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. FED. R. A PP. P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with FED. R. A PP. P. 32.1

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No. 25-2968 Page 2
We draw the following facts from Williams’s complaint. Williams suffers from
various disabilities, including rheumatoid arthritis and lupus. In May 2022, she was
hired by Tangoe US, Inc., a software company, to work as a product marketing
manager. In September, she sought accommodations for her disabilities. Tangoe told
her that the only documentation it needed was a letter from her physician, though it
later asked Williams to submit all her medical records. Williams instead provided only
records that she said were relevant to her claimed disabilities. Williams and Tangoe
could not come to an agreement on her accommodations, and she took medical leave
later in 2022 to treat her conditions. When she sought to return to work in March 2023,
initially on a part-time basis, Tangoe permitted her to return only if she could work
full-time. She did not return. In June, Tangoe told Williams that her position was being
eliminated.
In July 2024, Williams sued Tangoe for failure to reasonably accommodate her
disability and discrimination on the basis of requesting accommodations in violation of
the Americans with Disabilities Act, see 42 U.S.C. § 12112(b)(5)(A)–(B); retaliation for
seeking accommodations and complaining of discrimination in violation of Title VII of
the Civil Rights Act of 1964, see id. § 2000e-3; and age discrimination in violation of the
Age Discrimination in Employment Act, see 29 U.S.C. § 623.
Discovery ensued, and the parties disputed the scope of medical records that
Tangoe could access. Tangoe requested, among other things, that Williams produce all
documents relating to her claim that she is disabled, and that she authorize her
healthcare providers to respond to Tangoe’s subpoenas for medical records. Williams,
however, provided records from only three of her providers, and she objected that the
request to authorize disclosures was overbroad. Tangoe then moved to compel
Williams to produce these records and to sign the authorizations. See FED. R. CIV. P.
37(a).
The district court convened a hearing on this motion. The court ordered Williams
to produce her medical records and authorize disclosure by June 30, and it directed the
parties to agree on an order protecting the confidentiality of her records. The court
eventually entered protective orders allowing the parties to designate evidence as
confidential.
Williams did not comply with the order to produce her records and authorize
disclosures. Instead, on her deadline to comply, she asked for an extension based on her
recent request that her attorney withdraw from the case. On July 14, the court held a
hearing on this request for an extension, ordered Williams to provide the disclosure

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No. 25-2968 Page 3
authorizations within two days, and warned her that failure to comply could result in
the dismissal of the case.
Two days later, Williams, now proceeding pro se, instead filed a motion to
reconsider the order compelling discovery. In that motion, she argued that only two of
the seven conditions she listed in her response to Tangoe’s interrogatories—rheumatoid
arthritis and lupus—constituted disabilities for the purpose of her claim, and so
discovery should be limited to evidence related to those two conditions. Tangoe
responded by moving for the court to dismiss the case as a sanction for discovery
violations. See FED. R. C IV. P. 37(b), 41(b).
On August 5, the court convened a third hearing on these motions. In response to
Williams’s argument, the court concluded that all her medical records were relevant
(because they might include evidence that could prove or disprove the existence of her
two claimed disabilities), ordered Williams to provide the release authorizations within
three days, and warned her again that failure to comply would result in dismissal of the
case with prejudice. After Williams responded by filing a “notice of voluntary dismissal
without prejudice,” Tangoe renewed its request to dismiss the case as a sanction.
The court then dismissed the case with prejudice. The court acknowledged that
dismissal with prejudice is a drastic sanction but deemed it appropriate because (1) it
had warned Williams repeatedly that failing to follow court orders could result in the
dismissal of her case with prejudice; (2) Williams had acted willfully, in bad faith, and
with fault, in violation of Rule 37(b), for disobeying court orders to produce the signed
authorizations; and (3) Williams had engaged in a clear record of delay and
contumacious conduct, sufficient to warrant dismissal under Rule 41(b).
Williams then moved to amend the judgment, arguing in relevant part that
dismissal of her case under Rule 37(b) and 41(b) was a disproportionate sanction. The
court disagreed and denied this motion, highlighting her pattern of ignoring discovery
and other court orders.
On appeal, Williams contests the district court’s determination that her
disagreement with the scope of the court’s discovery order was evidence of bad faith, as
necessary to justify a dismissal under Rule 37(b). We review such a determination for
clear error, see Donelson v. Hardy, 931 F.3d 565, 569 (7th Cir. 2019), and see no error here.
A dismissal under Rule 37(b) is justified where, as here, a plaintiff willfully refuses to
comply with discovery orders, having already been warned that noncompliance may

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lead to dismissal. See Equal Emp. Opportunity Comm’n v. Wal-Mart Stores E., L.P., 46 F.4th
587, 601 (7th Cir. 2022).
Williams next maintains that the district court erred by not considering her
objection to the scope of discovery or the efficacy of lesser sanctions. But this
mischaracterizes the court’s rulings. The court considered her overbreadth challenge to
the scope of Tangoe’s discovery request but overruled it on grounds that her medical
records could prove or disprove her claimed disabilities. The court also contemplated
lesser sanctions but rejected them as ineffective, given her repeated foot-dragging when
directed to comply with court orders. Dismissal as a sanction is an appropriate remedy
when, as here, a plaintiff demonstrates a pattern of violating court orders, when others
are prejudiced by noncompliance with those orders, and when the court considers the
possible efficacy of lesser sanctions. See Pendell v. City of Peoria, 799 F.3d 916, 917
(7th Cir. 2015). Sanctioning Williams by dismissing her case was well within the court’s
discretion. Wal-Mart Stores, 46 F.4th at 599.
AFFIRMED

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