CHICAGO (CN) – A Wisconsin elementary school should have moved a teacher with seasonal affective disorder to a classroom with exterior windows, the 7th Circuit ruled.
Renae Ekstrand requested a switch in 2005 to teaching first grade at Somerset Elementary School after five years with the kindergarten class.
The first grade classroom had no exterior windows, however, and was located in a loud area of the school.
Shortly after the school year began, Ekstrand began experiencing symptoms of seasonal affective disorder, a form of depression.
Ekstrand wanted to switch rooms, but the principal tried only to make the existing classroom more hospitable.
On the recommendation of both her psychologist and primary care physician, Ekstrand took a three-month leave of absence for illness. Ekstrand claimed to have explained to school officials that she would be unable to teach unless she was assigned to a room with natural light.
When no reassignment occurred, Ekstrand extended her leave for the remainder of the 2005-06 school year. She also took leave for the 2006-07 school year.
Ekstrand then sued the School District of Somerset, alleging that it failed to accommodate her disability by assigning her to a different classroom violated the Americans With Disabilities Act.
Though U.S. District Judge Barbara Crabb initially granted summary judgment to the school district, the case went to trial on orders from the 7th Circuit.
A jury ultimately awarded Ekstrand more than $26,000 in back pay and benefits.
In the latest appeal, the school district claimed that Ekstrand had presented insufficient evidence at trial.
Crabb denied the motion, and the 7th Circuit affirmed on Wednesday.
“This challenge to the sufficiency of the evidence is particularly weak because we essentially decided these very same issues in Ekstrand’s favor the last time this case was before us,” Judge William Bauer wrote for a three-member panel. “When Ekstrand appealed the entry of summary judgment against her in 2009, we held that a genuine issue of material fact existed. … By that, we simply meant that Ekstrand had presented enough evidence for a reasonable jury to find in her favor on those issues.”
Unless some of those facts from 2009 had changed, there was no reason to overturn the prior ruling, Bauer said.