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Court OKs ADA claim for seasonal affective disorder

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CHICAGO—A teacher can sue her employer for not accommodating her seasonal affective disorder by failing to provide her a classroom with natural light, the 7th U.S. Circuit Court of Appeals has ruled.

Tuesday's ruling in Renae Ekstrand vs. School District of Somerset began with a February 2008 lawsuit in which Ms. Ekstrand alleged the school district failed to accommodate her disability and constructively discharged her under the Americans with Disabilities Act.

Events leading to the suit began during the 2005-2006 school year, when the woman requested to teach a different grade and was reassigned to a classroom with no exterior windows.

She advised the district of her disorder, and the district made some improvements to her classroom but did not move her despite the availability of two other classrooms, court records show.

The teacher experienced fatigue, anxiety, tearfulness and other symptoms and, as her condition worsened, her doctors placed her on medication and advised her to take a leave of absence.

A federal judge in Madison, Wis., granted summary judgment to the school district, holding that it engaged in an “interactive process” with the teacher in attempting to reduce her stress.

But the appeals court in Chicago cited evidence from Ms. Ekstrand's doctors showing that she was disabled. It also cited her psychologist's input that her attempt to return to work depended on providing her with natural light.

“Once aware of natural light's medical necessity to Ekstrand, and having been informed by Ekstrand only two weeks earlier that she was willing and able to return to work in a classroom with natural light, the school district was obligated to provide Ekstrand's specifically requested, medically necessary accommodation unless it ‘would impose an undue hardship' on the school district,” the appeals court ruled.

In overturning the lower court and remanding the case for further consideration, the appeals court said Ms. Ekstrand presented sufficient evidence for a jury to find that her employer failed to accommodate her under the ADA.

However, the appeals court upheld the trial court's dismissal of the constructive discharge allegation. “Ekstrand has not shown that the conditions of her employment even approached the intolerable levels normally required in constructive discharge,” the court said of her July 2007 resignation from the school district.