Where a discharged teacher’s teaching methods were not protected activity under Section 504 of the Rehabilitation Act, the lower court order was affirmed.The 7th U.S. Circuit Court of Appeals affirmed a decision by Chief U.S. District Judge James E. Shadid, Central District of Illinois.From August 2002 until May 2012, Michelle Frakes was a full-time special education teacher at Peoria Public Schools District 150. Beginning in August 2006, she was assigned to the Day Treatment Program, where she taught junior high …