Teacher’s Suit Over ‘Seasonal Affective Disorder’ Revived

By Mark Walsh — October 16, 2009 1 min read
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A federal appeals court has revived the lawsuit of a teacher who alleged that her Wisconsin school district failed to accommodate her “seasonal affective disorder.”

Teacher Renae Ekstrand’s suit alleged that the artificially-lighted classroom she was provided exacerbated her disorder, which is a form of depression, to the point where she experienced anxiety, fatigue and other problems, leading her to take a leave of absence. Her suit alleged that the Somerset school district violated the Americans with Disabilities Act by failing to assign her to a classroom with natural light.

A federal district court granted summary judgment to the school district, concluding that it had tried to respond to the teacher’s concerns. But in an Oct. 6 decision in Ekstrand v. School District of Somerset , a panel of the U.S. Court of Appeals for the 7th Circuit, in Chicago, restored her suit.

The panel held unanimously that the district could not have initially known that a classroom with natural light was the only effective accommodation for a teacher with seasonal affective disorder. But Eckstrand eventually presented information from one of her doctors that natural light was key to her improvement.

“Once aware of natural light’s medical necessity to Ekstrand, and having been informed by Ekstrand only two weeks earlier that she was willing and able to return to work in a classroom with natural light, the school district was obligated to provide Ekstrand’s specifically requested, medically necessary accommodation unless it would impose an undue hardship on the school district,” the appeals court said.

The district faced little hardship because a teacher with a natural-light classroom was willing to switch with Ekstrand, and empty classroom was also available, the court said.

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A version of this news article first appeared in The School Law Blog.