Seventh Circuit Affirms ADA Verdict Based on Seasonal Affective Disorder
July 13, 2012
Seasonal Affective Disorder (SAD) is a form of depression triggered by diminishing daylight during certain times of the year, especially in northern areas. Last month, the Seventh Circuit Court of Appeals upheld a $133,000 verdict against a school district for failure to accommodate a teacher diagnosed with SAD.
In Ekstrand v. School Dist. of Somerset, the plaintiff informed her employer that she suffered from SAD, and requested that her classroom be moved from an interior area of the school building to one with more exposure to natural light. She provided medical information from her psychologist and her primary care physician supporting the request. When the school denied the request and placed the plaintiff on medical leave, she sued, alleging failure to provide reasonable accommodation under the Americans with Disabilities Act.
The Seventh Circuit affirmed the jury verdict, concluding that the plaintiff was a qualified disabled individual under the ADA. The court also noted that the school could have switched classrooms with another teacher, or reassigned the plaintiff to a vacant room on the outside of the building. Either accommodation would have imposed minimal cost on the school.
In many situations involving mental disabilities, the employer is skeptical about the existence of the condition, or the real need for accommodation, especially in cases involving unusual disorders such as SAD. In other situations, the employer is hesitant to deal with mental disabilities, or loses confidence in the employee's ability to effectively perform the job.
As this case points out, the ADA does not distinguish between mental disabilities such as SAD, and physical disabilities that an employer may accommodate without second thought. In the absence of clear medical information contradicting the plaintiff's assertion of a disabling condition, the employer risks serious legal consequences by simply dismissing their accommodation request.