A school district failed to accommodate a teacher with seasonal affective disorder, the 7th U.S. Circuit Court of Appeals has determined, upholding a jury’s award of damages.
The 7th Circuit had already heard the case, Ekstrand v. School District of Somerset (No. 11-1949, June 26, 2012), once before. Renae Eskstrand filed suit against her employer, the School District of Somerset, Wis., after it refused to reassign her to a classroom with windows to accommodate her seasonal affective disorder, a type of depression often ameliorated by exposure to natural light.
A federal district court dismissed her claims and she appealed to the 7th Circuit. The appeals court, however, questioned whether an individual with fatigue, anxiety, panic attacks, uncontrollable crying and thoughts of suicide could even be qualified for an elementary teaching position — a prerequisite to proceeding with an Americans with Disabilities Act claim. It remanded the case for a jury trial.
The jury determined that Ekstrand was qualified and that the school district failed to accommodate her, in violation of the Americans with Disabilities Act and awarded her $2 million. The court, however, had to reduce the award to meet the law’s statutory cap. She ultimately received $100,000, back pay and attorneys’ fees.
The school district then appealed, arguing that there was insufficient evidence for a jury to determine that Ekstrand was qualified. The appeals court, however, disagreed. Last time, “we held that a genuine issue of material fact existed … as to whether … Ekstrand was a qualified individual with a disability during the relevant time period,” the court said. “By that, we simply meant that Ekstrand had presented enough evidence for a reasonable jury to find in her favor.”
For additional information about leave and disability, see Thompson’s employment law library including the ADA Compliance Guide.