School District Loses Seasonal Affective Disorder ADA Appeal
The Seventh Circuit Court of Appeals ruled against a Wisconsin school district in a Federal Rule of Civil Procedure 50(b) appeal this week, finding that there was sufficient evidence to support a jury verdict that a teacher suffering from seasonal affective disorder was entitled to reasonable accommodation under the American with Disabilities Act (ADA).
In the fall of 2005, after the school year began, elementary school teacher Renae Ekstrand began to experience symptoms of seasonal affective disorder, a form of depression. Ekstrand spoke with the school principal several times to request a different classroom with exterior windows. Though the principal tried to make Ekstrand's classroom more hospitable, she denied the room change requests.
Both Ekstrand's psychologist, Dr. Randi Erickson, and her primary care physician Dr. Arnold Potek, recommended that she take a leave of absence due to illness. Her initial leave was only three months, but it was later extended to continue through both the 2005-2006 and 2006-2007 school years.
Ekstrand subsequently sued the School District of Somerset, Wisconsin, under the ADA, alleging that the school district failed to make a reasonable accommodation for her disability.
The school district moved for summary judgment, which the district court granted. The Seventh Circuit Court of Appeals reversed that ruling in part, holding that there was a triable issue of fact as to whether Ekstrand was a qualified individual with a disability within the meaning of the ADA and as to whether the school district was aware of that disability.
The case went to trial, and jury returned a verdict in favor of Ekstrand. The school district moved for judgment as a matter of law under Rule 50(b), challenging the sufficiency of the evidence. The district court denied the motion, and the school district appealed. Monday, the Seventh Circuit affirmed the district court.
There were two questions before the appellate court: whether there was sufficient evidence for a jury to find that Ekstrand was a qualified individual with a disability under the ADA, and whether there was sufficient evidence for a jury to find that the school district knew of that disability within the relevant time period.
The Seventh Circuit noted that the school district's sufficient evidence challenge was particularly weak because the court essentially decided the very same issues in Ekstrand's favor in the 2009 summary judgment appeal. Just as there was sufficient evidence for a possible verdict in Ekstrand's favor on the issues in the last appeal, the court found that there was ample evidence at the post-trial stage for a reasonable jury to have found in Ekstrand's favor.
If you're attempting a Rule 50(b) appeal before the same court that previously ruled that there was sufficient evidence in a case to withstand summary judgment, just remember that you're facing an uphill battle.
- Renae Ekstrand v. School District of Somerset (Seventh Circuit Court of Appeals)
- Fifty Shades of Appeals: What is Sufficient Evidence of Extortion? (FindLaw's Sixth Circuit Blog)
- What is a Reasonable Accommodation? (FindLaw's Free Enterprise)
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