Sharon Walker (“Walker”), a high school business teacher, brought suit against the Pulaski County Special School District (“PCSSD”) claiming that she had been discriminated against and retaliated against because of her disability in violation of the American with Disabilities Act (“ADA”). PCSSD filed a motion for summary judgment, and on May 1, 2017, it was granted by the U.S. District Court for the Eastern District of Arkansas.
Walker originally taught economics and business law courses at the high school, but in 2014 she was assigned to also teach an alternative learning environment (ALE) class. Walker immediately filed a grievance with PCSSD asserting that the ALE assignment would result in a heavy workload. According to Walker’s Complaint, this workload caused her to suffer severe depression, anxiety, and obsessive-compulsive disorder. As a result of her condition, Walker took leave in December 2014 and did not return to teaching for the remainder of the 2014-15 school year.
For the 2015-16 school year, PCSSD assigned Walker to teach a “double block” Algebra I class. On June 10, 2015 Walker’s clinical psychologist sent a letter to PCSSD stating that the “double block” Algebra I classes would be too stressful for Walker and recommended that PCSSD accommodate Walker by assigning her to a Business Education class. In response to this letter, PCSSD offered Walker a position teaching all business courses at a separate high school, which was part of the PCSSD school district, but slated to detach in the following school year. Walker refused the offer. She claimed that not knowing for sure that she would have a position for the following school year was too stressful, even though PCSSD only issued one-year employee contracts. Walker unsuccessfully applied for three other PCSSD teaching positions for the 2015-16 year.
On August 13, 2015, PCSSD sent Walker a letter informing her that if she wasn’t released to return to work on September 3, 2015, or if PCSSD did not hear from her, it would be assumed that she resigned. Walker did not return to PCSSD, instead she accepted employment as a special education teacher with another school district and brought her case against PCSSD.
The threshold inquiry in disability discrimination cases is whether the claimant has a disability within the meaning of the ADA. “Disability” under the ADA is defined as “a physical or mental impairment that substantially limits one or more of the major life activities of such individual…” 42 U.S.C. §12102(2). Working is considered a major life activity. 29 C.F.R. §1630.2(i). Consequently, a substantial limitation on the major life activity of working means that an individual must be “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes.” 29 C.F.R. §1630.2(j)(3)(i).
After reviewing the facts, the Court found that Walker has not shown that she was disabled for purposes of her ADA failure to accommodate and unlawful discharge claims because there was no evidence that she was substantially limited in her ability to work. This determination was based on the fact that Walker had been offered two teaching positions, which she had rejected, and, at the time of the decision, she was gainfully employed as a special education teacher in another school district. Furthermore, the Court found that there was no evidence that PCSSD failed to offer her a reasonable accommodation because it offered her the business teacher position in the different high school. PCSSD was not obligated to provide the accommodation requested or preferred by Walker.