A. PARTIES
1. Complainant Deetreal Prateet is a law-abiding female adult citizen of sound mind and a
resident of the State of Illinois. Ms. Prateet is a quadriplegic/ambulate with crutches.
2. Defendant U.S. Bank is a bank providing financial services in the City of Chicago.
B. STATEMENT OF FACTS
3. On or around May 21, 2022, Ms. Prateet called U.S. Bank to open an account. She
inquired if the bank’s premises had proper parking accommodations for disabled persons
and was informed they were available.
4. When she arrived at the parking lot, it was not accessible or safe at all as was earlier
promised by U.S. Bank’s staff.
5. U.S. Bank sent someone to assist Ms. Prateet. She opened her account and was assisted
back to her car as she did not feel safe.
6. Ms. Prateet sent a complaint but U.S. Bank but she has never received a response.
7. Around July or August, U.S. Bank restriped its parking lot and the accessible parking
spot was completely removed.
C. ARGUMENT
8. Ms. Prateet hereby incorporates by reference ¶ 1-7 of this Complaint as though set out in
full herein.
9. Chicago Municipal Code § 2-160-020(c) defines disability as a determinable physical or
mental characteristic which may result from disease, injury, congenital condition of birth
or functional disorder including, but not limited to, a determinable physical characteristic
which necessitates a person’s use of a guide, hearing or support dog.
10. Ms. Prateet is a quadriplegic/ambulate with crutches, and fits the definition above.
Therefore, she has standing to bring this matter.
11. Chicago Municipal Code § 2-160-020(j) defines public accommodation as a place,
business establishment or agency that sells, leases, provides or offers any product, facility
or service to the general public, regardless of ownership or operation (i) by a public body
or agency; (ii) for or without regard to profit; or (iii) for a fee or not for a fee. An
institution, club, association or other place of accommodation which has more than 400
members, and provides regular meal service and regularly receives payment for dues,
fees, accommodations, facilities or services from or on behalf of nonmembers for the
furtherance of trade or business shall be considered a place of public accommodation for
purposes of this chapter.
12. U.S. Bank is a public accommodation by the definition above.
13. Chicago Municipal Code § 2-160-070 provides as follows: “No person that owns, leases,
rents, operates, manages or in any manner controls a public accommodation shall
withhold, deny, curtail, limit or discriminate concerning the full use of such public
accommodation by any individual because of the individual’s race, color, sex, gender
identity, age, religion, disability, national origin, ancestry, sexual orientation, marital
status, parental status, military discharge status, or source of income.”
14. The above provision places a duty on U.S. Bank to provide accommodation for disabled
persons. That duty is owed to all disabled persons who may use its facilities.
15. U.S. Bank owed Ms. Prateet a duty to ensure that there was parking that could
accommodate her disability. Before she went to U.S. Bank, she called to inquire if the
bank had appropriate parking accommodation. U.S. Bank confirmed that indeed it was
available.
16. When Ms. Prateet arrived at U.S. Bank, there was no parking to accommodate her
disability and she had to be helped into and out of the bank.
17. U.S. Bank breached its duty by failing to provide Ms. Prateet with parking
accommodation for her disability. The bank discriminated against Ms. Prateet as well as
other disabled persons who might want to access the bank, when it failed to provide
parking accommodation for persons with disability.
18. Further, U.S. Bank restriped its parking lot and the accessible parking spot was
completely removed in total disregard of disabled persons.
19. U.S. Bank is liable for disability discrimination and ought to pay damages to Ms. Prateet.
D. PRAYER FOR RELIEF
REASONS WHEREFORE, PREMISES CONSIDERED, Ms. Prateet respectfully requests this
Honorable Commission to GRANT her the following reliefs:
a. AWARD judgment in favor of Ms. Prateet and against U.S. Bank;
b. AWARD Ms. Prateet damages for disability discrimination in the sum of
$____________;
c. AWARD Ms. Prateet punitive damages;
d. AWARD Ms. Prateet costs of this suit;
e. AWARD Ms. Prateet pre- and post-judgment interests;
f. AWARD Ms. Prateet such further relief as this Commission deems proper.
Dated this ____ day of September, 2022.
Respectfully Submitted,
___________________________________
Deetreal Prateet,
Complainant
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