Lawler v. Peoria Sch. Dist. No. 150, No. 15-2976 (7th Cir. 2016)
Annotate this CaseLawler was diagnosed with posttraumatic stress disorder (PTSD) five years before the Peoria School District hired her to teach students with learning disabilities. For nine years, Lawler performed that job satisfactorily and was given tenure. In 2010, her psychiatrist concluded that Lawler had suffered a PTSD relapse and the District first learned about her impairment. After that Lawler was transferred to a different school to teach children with learning disabilities and also severe emotional and behavioral disorders. Both Lawler and her new supervisor thought she was ill-prepared for this role, but the District did not relent. After a year in the new position, Lawler was rated as “satisfactory.” At the start of her second year, she was injured by a disruptive student, sending her to the hospital with a concussion and neck injury. Her psychiatrist notified the District that this and other incidents had retriggered Lawler’s PTSD and that she needed to be transferred. The District did not transfer Lawler but accelerated her next performance appraisal, rated her as unsatisfactory, and fired her as part of an announced reduction in force that ended with all but “unsatisfactory” teachers being rehired. Lawler filed suit under the Rehabilitation Act, 29 U.S.C. 794, claiming failure to accommodate her PTSD and termination in retaliation for requesting an accommodation. The district court granted the District summary judgment. The Seventh Circuit vacated. A jury reasonably could find that the District failed to accommodate Lawler’s PTSD.
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