Federal appellate court’s ruling sustains jury verdict in favor of teacher with seasonal affective disorder claiming ADA violation

Ekstrand v. School Dist. of Somerset, No. 11-1949 (7th Cir. June 26, 2012)

Abstract: A three-judge panel of the U.S. Court of Appeals for the Seventh Circuit (IL, IN, WI) affirmed a Wisconsin federal district court’s decision to deny a school district’s motion for judgment as a matter of law, letting stand a jury verdict in favor of a teacher with seasonal affective disorder who claimed the school district failed to accommodate her disability in violation of the Americans with Disabilities Act (ADA).

Facts/Issues: Renae Ekstrand taught kindergarten at Somerset Elementary School from 2000 to 2005. In Spring 2005, she asked to be reassigned to teach first grade and was given a classroom with no exterior windows. Ekstrand made several requests to change classrooms, but her requests were denied though her principal made efforts to make the existing classroom more hospitable. After school began in fall 2005, Ekstrand began experiencing symptoms of seasonal affective disorder, a form of depression. Ekstrand’s psychologist and primary care physician suggested that she take a leave of absence which initially lasted from about October 2005 to January 2006. This is the time period at issue for the Second Circuit in this opinion, though her medical leave of absence was later extended for the rest of the 2005-2006 school year.

During that initial period of leave, Ekstrand had conversations with both her principal and district superintendent about the importance of natural light in her classroom for her recovery, and she reiterated her requests for a classroom change. In November 2005, Ekstrand’s psychologist sent a letter to the school district’s office which also explained the need for natural light, and that her classroom without windows had been a major cause of her condition. Still no change was made. The following winter, Ekstrand’s doctor wrote to the school district that Ekstrand would be unable to return for the remainder of the 2005-2006 school year. That leave of absence was further extended to include the 2006-2007 school year.

Ekstrand filed suit under the ADA, claiming that the school district failed to accommodate her disability of seasonal affective disorder.  The district court initially granted the school district’s motion for summary judgment. Ekstrand appealed to the Seventh Circuit, which reversed in part in October 2009. In that ruling, the Seventh Circuit held that there was a triable issue of fact as to whether Ekstrand was a qualified individual with a disability under the ADA, and as to whether the school district was aware of her disability. At trial in the district court, the jury returned a verdict in favor of Ekstrand, prompting the school district to move for judgment as a matter of law, challenging the sufficiency of the evidence. The district court denied the school district’s motion. The school district brought a second appeal before the Seventh Circuit challenging the district court’s denial of the school district’s motion.

Ruling/Rationale: The unanimous three-judge panel affirmed the district court’s denial of the school district’s motion. The panel confined its discussion to the school district’s two specific challenges: (1) whether there was sufficient evidence for a jury to find that Ekstrand was a qualified individual with a disability under the ADA, and (2) whether there was sufficient evidence for a jury to find that the school district knew of that disability within the relevant time period.

At the outset of its analysis, the panel stated that in reviewing the denial of the school district’s motion for judgment as a matter of law, the panel views the evidence available to the jury in the light most favorable to Ekstrand, and that they will only reverse if no reasonable juror could have found in Ekstrand’s favor. The panel also specifically noted that it is “generally forbidden from reexamining the facts found by the jury at trial.”

The panel stated that at trial, Ekstrand bore the burden of proving that (1) she was a qualified individual with a disability; (2) the school district was aware of her disability; and (3) the school district failed to reasonably accommodate that disability. The school district only challenged the first two elements, arguing that no reasonable jury could have found for Ekstrand on those grounds.

The panel, however, identified “several conclusions that reasonable jurors may have drawn given the evidence in the case”: the jurors may have credited Ekstrand’s own testimony over the superintendent’s on key issues; they may have found Ekstrand’s psychologist’s testimony convincing; and they may have decided not to credit the superintendent’s testimony that he was late in reading the psychologist’s letter regarding the importance of natural light in Ekstrand’s recovery. The panel said that “[t]aken together, these determinations could lead a reasonable jury to conclude that Ekstrand was a qualified individual with a disability in October through early December [2005] and that the school district knew about it, but failed to accommodate her with a new classroom.” The panel stated that “Ekstrand’s case was convincing to these jurors, and the school district cannot now retry the case in the appellate court.”

The panel stated it was essentially being asked to decide the same issues that it had previously decided in Ekstrand’s favor the last time this case was before it when Ekstrand appealed the entry of summary judgment against her, making the school district’s second challenge to the sufficiency of the evidence very weak.

Ekstrand v. School Dist. of Somerset, No. 11-1949 (7th Cir. June 26, 2012)

[Editor's Note: In October 2011, Legal Clips summarized an article from the Courthouse News Service, which reported that a Wisconsin jury in federal district court had awarded Ekstrand $353,000 in damages based on her claims that she was mistreated and ultimately fired because of her disabilities. Ekstrand's initial complaint can be found here.]

Tags: , , , , , ,