Appeals Court Rules on ADA and Seasonal Affective Disorder

Locating an employee who has seasonal affective disorder near exterior windows can be a reasonable accommodation under the Americans with Disabilities Act, according to a federal court.

A Wisconsin elementary school moved a kindergarten teacher to a windowless classroom when it assigned the teacher, at her request, to a first-grade class located in a room lit exclusively with artificial light. The teacher had severe seasonal affective disorder, a type of depression that is triggered and intensified by lack of natural light. She requested a classroom with exterior windows before she made the move, and after school started, she repeatedly asked the school principal to reassign her to a room with natural light because of her condition.

Although another teacher had offered to trade rooms with her and an empty classroom was available, the school did not reassign the SAD-afflicted teacher to a different classroom. Her health declined, and she suffered symptoms such as panic attacks, disorganization, inability to eat and suicidal thoughts. She took medical leave, and while she was on leave, she continued to request a transfer to a naturally lit classroom. By the end of the Thanksgiving break, she had been on leave for more than a month, and her psychologist provided written verification of her need for light to the school.

A few months later, the teacher sued the school for failing to reasonably accommodate her disability. The school won the lawsuit, but the teacher appealed. The Seventh Circuit Court of Appeals recently overturned the school's victory. The court said that once the teacher had made the school aware of her disability by her psychologist's verification of her condition, the school had an obligation to provide a reasonable accommodation. Moving the teacher to a different classroom, the court said, would not have imposed an undue hardship on the school. The case drives home the importance of recognizing a report of a disability from an employee or her medical provider, especially when the disability is not obvious.

Categories: Workplace Compliance
Tags: ADA