11-21-2016
Eymarde Lawler taught students with learning disabilities in Peoria School District No. 150 (“Peoria”). Her employment with Peoria was always satisfactory until she suffered a relapse of her Post Traumatic Stress Disorder (“PTSD”). The PTSD was brought on by a problematic relationship with the principal of her school. She asked for a leave of absence. It was at this point that Peoria first learned of her PTSD. Ms. Lawler’s psychiatrist recommended that she be transferred to another school for her mental health.Ms. Lawler was transferred to a Day treatment program. This program was to “teach children with not only learning disabilities by also severe emotional and behavioral disorders.” Both she and her new principal agreed that it was not a suitable position for her. At the beginning of her second year in that position, she was unintentionally thrown against the wall by a disruptive student, which caused a concussion. This incident further triggered her PTSD. After consulting with her psychiatrist, she requested a leave and another transfer. This time Peoria did not accommodate her request. Instead, it accelerated her performance review. She was reviewed as unsatisfactory and she was fired. The review criticized her for being abrasive and behaving inappropriately with co-workers and students.
The Seventh Circuit Court of Appeals ruled against the school district, finding that Peoria should have engaged in an interactive process with Ms. Lawler. In that process, Peoria would have learned that many of the issues relied upon in her performance review were caused by her PTSD. The psychiatrist noted that her “PTSD was being aggravated by working with students who had severe behavioral and emotional disorders.” The record also showed that that Peoria had approximately seven other openings in the district for special education teachers.