Renae Ekstrand v. School District o
683 F.3d 826
7th Cir.2012Background
- Ekstrand taught kindergarten at Somerset Elementary; requested reassignment to a first-grade class in 2005 and was moved to a windowless room.
- Ekstrand and school officials discussed classroom changes; requests were denied and no exterior windows were provided.
- In fall 2005, Ekstrand developed seasonal affective disorder; doctors recommended leave and extended leaves followed for 2005-06 and 2006-07.
- Letters from Ekstrand’s psychologist/physician emphasized need for natural light and linked a windowless room to her condition, with actual return feasibility tied to light.
- Trial evidence suggested the district’s awareness of Ekstrand’s disability and potential for return if placed in a well-lit room; some officials did not timely review key medical communications.
- The district court granted summary judgment, which was partially reversed on appeal; a jury found in Ekstrand’s favor, and the district challenged Rule 50(b) denial on sufficiency grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Ekstrand a qualified individual with a disability? | Ekstrand shown qualified under ADA. | District disputes qualification. | Sufficient evidence supports qualification. |
| Did the district know of Ekstrand’s disability in the relevant period? | District was aware or should have been aware. | Awareness not shown sufficiently. | Sufficient evidence supports knowledge. |
Key Cases Cited
- Ekstrand v. School Dist. of Somerset, 583 F.3d 972 (7th Cir. 2009) (reaffirmed issue of disability and awareness at summary-judgment stage)
- King v. City of Madison, 550 F.3d 598 (7th Cir. 2008) (ADA burden includes qualification, awareness, and accommodation)
- Waters v. City of Chicago, 580 F.3d 575 (7th Cir. 2009) (standard for reviewing Rule 50(b) denial on de novo review)