Eymarde Lawler v. Peoria School District No. 150
837 F.3d 779
7th Cir.2016Background
- Lawler, a tenured special-education teacher with a long history of PTSD in remission, was reassigned in 2010 to a Day Treatment program for students with severe behavioral and emotional disorders.
- After a 2011 incident in which a student injured Lawler, her psychologist stated her PTSD was "retriggered" and recommended a two-week leave plus reassignment to a less behaviorally intensive classroom.
- Human Resources granted a two-week medical leave but (according to Lawler) refused to consider a transfer; the district disputes timing and says required paperwork was not completed.
- Lawler returned to work, received an "unsatisfactory" evaluation in February 2012, was disciplined twice during the year, placed in the first group for a RIF, and was discharged when the district implemented reductions in force.
- Lawler sued under the Rehabilitation Act for failure to accommodate and retaliation; the district court granted summary judgment for the district. The Seventh Circuit vacated and remanded on the failure-to-accommodate claim, finding genuine disputes about whether the district engaged in the required interactive process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district failed to engage in the ADA/Rehab Act interactive process to accommodate Lawler's PTSD | District refused to consider transfer and did not explore reasonable accommodations after doctor requests; two-week leave was insufficient | District provided reasonable accommodation by granting a two-week medical leave and interpreted Lawler's return communications as withdrawing transfer request; also argues paperwork was not completed | Reversed: jury could find district failed to engage in the interactive process and that mere two-week leave was insufficient without further inquiry |
| Whether Lawler's state-court suit precluded her federal claims (res judicata/claim-splitting) | Not preclusive because district acquiesced to claim-splitting by delaying its defense; the federal Rehab Act claim was distinct from the state School Code claim | Argues final state judgment bars federal claims | Rejected: Seventh Circuit held district’s delay amounted to acquiescence and the federal claims were not precluded |
| Whether employer reasonably relied on ambiguous communications from employee/doctor instead of seeking clarification | Lawler: employer should have sought clarification when in doubt and could not assume she abandoned transfer request | District: interpreted Lawler's e-mail and doctor’s return note to mean accommodation no longer needed; relied on employee communications | Held: employer had duty to clarify; reasonable jury could find failure to seek clarification caused breakdown in interactive process |
| Whether reassignment to a vacant position was a realistic accommodation the district should have considered | Lawler: vacant special-education openings existed and reassignment is a recognized accommodation | District: did not pursue reassignment; implies procedural/paperwork issues | Held: jury could conclude reassignment was feasible and district should have explored it |
Key Cases Cited
- Sears, Roebuck & Co. v. E.E.O.C., 233 F.3d 432 (7th Cir.) (summary judgment evidence must be viewed in light most favorable to nonmovant)
- Spurling v. C & M Fine Pack, Inc., 739 F.3d 1055 (7th Cir. 2014) (employer must engage in interactive process and seek clarification when needed)
- Beck v. Univ. of Wis. Bd. of Regents, 75 F.3d 1130 (7th Cir. 1996) (both parties must make good-faith efforts in the interactive process)
- Miller v. Ill. Dep’t of Corr., 107 F.3d 483 (7th Cir. 1997) (employer must make reasonable efforts to explore accommodation possibilities)
- Bultemeyer v. Fort Wayne Comm. Schs., 100 F.3d 1281 (7th Cir. 1996) (employer put on notice by performance decline must consider accommodations)
- Walczak v. Chicago Bd. of Educ., 739 F.3d 1013 (7th Cir. 2014) (res judicata and claim-splitting principles in context of state vs federal claims)
- Migra v. Warren City Sch. Dist. Bd. of Educ., 465 U.S. 75 (1984) (federal courts must give state judgments the same preclusive effect as state courts)