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7th Circuit Affirms Jury's Verdict that School District Violated the ADA by Failing to Accommodate Seasonal Affective Disorder, by Barbara Halpin
The 7th Circuit recently affirmed a jury's decision that a Wisconsin school district violated the Americans with Disabilities Act (ADA) for not accommodating a teacher's seasonal affective disorder.
The teacher, Renae Ekstrand, sued the Somerset Wisconsin school district for failing to accommodate her disability. Initially, the jury held in favor of Ekstrand and subsequently the district moved for judgment as a matter of law challenging the sufficiency of the evidence. The district court denied the district’s motion and the school district appealed to the 7th circuit which upheld the court’s decision.
As factual background, the plaintiff taught kindergarten at Somerset Elementary school from 2000 to 2005. When she was transferred to teach first grade her new classroom was an interior classroom with no windows. She asked the principal several times to change classrooms so she would be exposed to natural light. After experiencing symptoms of seasonal affective disorder in fall 2005, both her psychologist and her primary care physician recommended that she take a three month leave of absence. Her disorder became so severe that she, with the recommendation of her physicians, was not able to return to work for the rest of the 2005-2006 school year, nor the 2006-2007 school year.
At trial the evidence most damning to the district was that her psychologist wrote letters to the school district during her initial three month leave of absence stating that natural light “was crucial” to her recovery and the classroom had been a “major cause” of the disorder. The district refused to move her classroom.
The 7th Circuit’s discussion was brief. It held that Elkstrand proved the burden of proof under the ADA; “(1) that she is a qualified individual with a disability; (2) the school district was aware of her disability; and (3) the school district failed to reasonably accommodate that disability.” The Court wrote that a reasonable jury clearly had sufficient evidence in this case, including the testimony of her psychologist that had she received a classroom with light, she could have returned to work.
This case seems to hinge on the notion that the school district both knew about the condition and how to fix it. It’s important for employers, both public and private, to take disability claims seriously. To read the decision, click here.