A Dreary Classroom Is Cause for a Lawsuit

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Business and Operations//

January 22, 2010

During this time, there were two other classrooms that fit her requests.

As the school year progressed, Ekstrand began experiencing fatigue, anxiety, hypertension, an inability to concentrate, and thoughts of suicide. Her physician suggested she take a leave of absence. Twice during her leave, she again requested to move her class into another available classroom.

After being denied again to be moved into another classroom, Ekstrand's doctor wrote a letter to the school district's workers' compensation claim representative explaining the "importance of natural light for individuals with a history of this disorder." He stated in his letter that her most recent episode of depression was most likely due to her lack of exposure to natural light.

The final outcome? Ekstrand continued to suffer from deepened depression, eventually making it impossible for her to continue working. Not being capable of working, Ekstrand brought charges against the school district, claiming it failed to accommodate her SADD, and had constructively discharged her in violation of the ADA. The district court granted summary judgment to the school district on both counts.

Ekstrand appealed.

The 7th Circuit Court of Appeals reversed the district court's grant of summary judgment on the failure-to-accommodate claim, and affirmed the district court's grant of summary judgment on the constructive discharge claim.

Regarding the failure-to-accommodate claim reversal, the 7th Circuit stated that the letter submitted by Ekstrand's physician on November 28, 2006, clearly stressed her need for natural light in returning to work, and that the school district was obligated to provide her with the accommodation to aid in resolving her medical condition, as they had with her other issues. They also noted that little hardship would have been imposed in providing Ekstrand with an available classroom.

Regarding her constructive discharge claim, the 7th Circuit concluded that Ekstrand had not provided adequate proof that the condition of her employment even approached the intolerable levels normally required in constructive discharge claims.

Read more about Seasonal Affective Disorder here.

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