The Chicago Employment Law Blog

SAD Teacher Wins Appeal of ADA Case, Keeps Judgment

Seasonal Affective Disorder, or SAD, is a recurrent type of depression that happens at a certain time of the year for the affected person. It usually occurs during the winter, and is often treated by the use of special lamps or sunlight. It is thought that the depression is caused by a lack of exposure to sunlight and special lamps can recreate the benefits of sunlight.

Renae Ekstrand first noticed that she suffered from the disorder in 2005. Ekstrand taught first grade in a classroom that lacked windows. After experiencing the seasonal depression, and consulting with a physician, Ekstrand requested that the school give her a different classroom. Instead of making such a reasonable accommodation, they merely made attempts to make the room "more hospitable."

After a few months, she was eventually forced to take temporary leave for the remainder of the school year. The leave was extended through the following school year. After the school continued to fail to accommodate her medical condition, she sued under the Americans with Disabilities Act.

The Somerset School District won the first round, before a trial even occurred. The judge was unsympathetic to Ekstrand's claims and dismissed her case. However, the Seventh Circuit Court of Appeals overturned the lower court and ordered the trial to proceed. The jury sided with Ekstrand, who won more than $26,000 in back pay and benefits.

Undaunted, the school appealed the judgment. They felt that there was not enough evidence presented at trial to sustain a verdict. The Seventh Circuit disagreed; last week, it upheld the verdict.

A jury's decision is given deference and respect in our court system. A court can only overturn a jury's verdict if there is no possible way that a jury could have made that decision properly using whatever evidence was presented at trial.

The Seventh Circuit felt that there was enough evidence that a juror could find that the school knew of Renae Ekstrand's medical condition and that the medical condition actually existed. She had made multiple complaints and presented her doctor's note to the school, yet no reasonable accommodation, such as changing classrooms, was offered.

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