[authors: Amy Dickerson and Dana Fattore Crumle]
On June 26, 2012, the U.S. Court of Appeals for the Seventh Circuit upheld a jury verdict finding in favor of a teacher with seasonal affective disorder claiming a Wisconsin school district violated her rights under the Americans with Disabilities Act (ADA). The teacher claimed that the school district failed to accommodate her disability when it denied her repeated requests to relocate her class to a different classroom with exterior windows. The teacher spoke to school officials several times to request a change of classroom. She submitted a note from her doctor stating the importance of the teacher being exposed to natural light and that her classroom without windows was a major cause of her condition. Although officials attempted to make the existing classroom more “hospitable,” they denied her requests to switch rooms. As a result of her illness, the teacher’s psychologist and her primary care physician recommended she take a leave of absence, which was initially supposed to be only three months, but was later extended to the remainder of the school term and into the following term.
At trial, the teacher’s doctor testified that she would have been capable of returning to work during the first few months of her leave of absence if she had been provided a classroom with natural light. The principal also testified about the conversations he had with the teacher in which she requested a new room, but the superintendent testified that he never saw the doctor’s note describing the importance of natural light to her condition until her lawsuit was filed several months later, despite the note being delivered to his office’s business manager. The Seventh Circuit found this argument unpersuasive, and, held that a reasonable jury could have concluded that the teacher was a qualified individual with a disability during the relevant timeframe and that the District knew about the teacher’s condition and failed to accommodate her with a new classroom. This case illustrates the high standard that parties must overcome when seeking to overturn a jury verdict, and provides insight into how juries may treat evidence like the teacher’s doctor note and the superintendent’s review of the note.