Question

A schoolteacher was successful at teaching kindergarten for five years. She requested to teach first grade and was then reassigned to a classroom that had no exterior windows. She told the school principal that she suffered from seasonal affective disorder, a form of depression. She made numerous requests to be moved to a classroom with natural light, but the school refused to do so. She also presented the school district with a letter from her psychologist stating that her depression was being exacerbated by the lack of natural light. Another teacher who had been assigned to a classroom with exterior windows had offered to switch rooms. There was also one vacant room with exterior windows, but this room was being reserved for the possible addition of another class section. The woman’s health deteriorated. She suffered from significant inability to concentrate, organize her thoughts, retrieve words, make decisions, and focus on the needs of her students. She also experienced racing thoughts, panic attacks, uncontrollable crying, inability to eat, and thoughts of suicide. She went on medical leave. Eventually, she quit, went to work elsewhere, and sued. What should the court decide? Why?   (Your analysis should include a discussion of an employer’s responsibilities under the ADA.)

Answer 1

The appeals court reversed the district court’s grant of summary judgment to the school district on the teacher’s failure to reasonably accommodate disability claim. [However, summary judgment was affirmed on her additional claim that she was constructively discharged .] The parties apparently did not dispute that the teacher’s seasonal affective disorder was a disability. The plaintiff’s doctor notified the school district's workers' compensation claims representative of "the importance of natural light for individuals with a history of this disorder" and that "Mrs. Eckstrand's current episode of depression was most likely directly related to a change in her work location, to a room lacking any [exterior] windows." Prior to then, the plaintiff had not provided the school district with anything more than her own belief that natural light was necessary to accommodate her. Thus, there was no evidence that the school district knew natural light therapy was the only way to accommodate the plaintiff before the time.

However, once the district became aware of the medical necessity of natural light, and having been informed by the plaintiff 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. “Little hardship would have been imposed in providing Ekstrand an available classroom.” The school district would have experienced costs associated with switching the items in the two rooms and with performing any necessary readjustments specific to the teachers' respective curricula. If the teacher had been accommodated by providing the empty room, it would have experienced the costs of moving her items, plus the costs of switching and readjustment due to the room being needed for a new third-grade section reduced by the probability that creation of the third-grade section would not occur. These costs were judged to be modest.

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