It sounds almost like a contradiction in terms: a teacher who suffers from “pedophobia"—a debilitating fear of young children.
By all accounts, an Ohio teacher legitimately suffered from the condition, yet she worked successfully as a foreign-language teacher at the high school level for many years. Administrators in the 1,700-student Mariemont district had asked 63-year-old teacher Maria Waltherr-Willard to transfer to an elementary school position in 1997, which is when she told them about her pedophobia, with her psychologist and an independent psychiatrist confirming that her fear of younger children would disable her from doing her job in such an environment.
The trouble came in 2009, when Mariemont High School decided to move its French courses online. That meant the school no longer had a place for Waltherr-Willard, who taught multiple levels of French and an introductory Spanish class. That was the start of a clash that would lead to a lawsuit alleging disability and age discrimination.
School administrators met to figure out what to do with Waltherr-Willard. With no suitable opening available at the high school, Mariemont Superintendent Paul Imhoff decided to transfer Waltherr-Willard to the district’s lone middle school, court papers say. The teacher did not initially object to that assignment.
Around the same time, however, the superintendent and Waltherr-Willard clashed over reports that the teacher was complaining to parents about the shift of the French courses to the Web. Waltherr-Willard would later say in court papers that the superintendent screamed and lunged at her during a meeting and threatened to punish her.
Six months later, the teacher did not feel the middle school was a good fit and she sought to return to the high school as a full-time Spanish teacher. Imhoff said there were no suitable positions available. Waltherr-Willard then retired.
Waltherr-Willard later sued the school district alleging violations of the federal Age Discrimination in Employment Act of 1967 and the Americans with Disabilities Act of 1990.
Waltherr-Willard argued the district violated the ADEA by retaining a younger Spanish teacher at the high school while transferring her to the middle school. And she argued the school district failed to accommodate her pedophobia with a job at the high school.
A federal district court ruled for the school district on the teacher’s claims, and in a Feb. 11 decision in Waltherr-Willard v. Mariemont City Schools, a three-judge panel of the U.S. Court of Appeals for the 6th Circuit, in Cincinnati, unanimously affirmed the lower court.
The age-discrimination claim failed, the court said, because the Spanish teacher retained at the high school was only two years younger than Waltherr-Willard. “That age difference is not ‘substantial’ for the purposes of the ADEA,” the court said.
As for Waltherr-Willard’s pedophobia-based disability claim, the court said “the ADA requires an employer to accommodate a disabled employee, but it does not require unreasonable accommodations.”
“Here, Willard asked Mariemont to accommodate her pedophobia by employing her at the high school as a full-time Spanish teacher,” the court said. “But the high school already had one of those and did not need another.”
The district would have had to either create a new job at the high school or displace the existing Spanish teacher—accommodations the ADA does not require, the court said.
A version of this news article first appeared in The School Law Blog.