Teacher With Expired Teaching Certificate Was Not "Qualified" Within The Meaning Of The ADA

Johnson v. Board of Trustees, 2011 WL 6091313 (9th Cir. 2011)

Patricia Johnson, who had a history of depression and bipolar disorder, taught special education for a school district in Idaho for a decade. Before her teaching certificate expired in 2007, Johnson failed to take sufficient college courses to obtain a renewal of the certificate because she experienced a “major depressive episode.” As a result, the school district terminated Johnson’s employment. Johnson sued for discrimination under the Americans with Disabilities Act, claiming that her disability led to her inability to timely obtain the appropriate certification. The Ninth Circuit held that because Johnson was not a “qualified individual with a disability” under the ADA (because of her failure to obtain the certificate), the school district had no obligation to reasonably accommodate her alleged disability.

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