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SAD but true: A window may be ADA accommodation

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in Discrimination and Harassment,Employment Law,Human Resources,Leaders & Managers,Management Training

by Mindy Chapman, Esq.

As winter approaches, it’s getting dark sooner each day. And with the darker season comes struggles for employees who suffer from Seasonal Affective Disorder (SAD). SAD is a form of depression in which a decrease of natural light triggers a mood disorder.

So does that mean you may have to offer SAD sufferers a workspace near sunlight? Quite possibly, as a recent court ruled, “Natural light may be a medical necessity.”…

Case in Point: First-grade teacher Renae Ekstrand worked happily at a Wisconsin school until she was transferred to a classroom without exterior windows.

Ekstrand asked to be moved. Before her school year, she gave the principal a doctor’s note that explained she suffered from SAD and had difficulty functioning in a room that lacked natural light. The principal denied her request, even though a classroom with natural light sat empty and another teacher offered to switch rooms.

Eventually, Ekstrand went on medical leave for depression. While on leave, she again requested a classroom with natural light. These requests were ignored. She missed two school years before taking another teaching job elsewhere.

Ekstrand sued under the Americans with Disabilities Act (ADA), saying the school failed to offer a reasonable accommodation for her disability, as the law requires. The school argued that Ekstrand didn’t have a qualifying disability.

The court sided with Ekstrand and sent the case to a jury trial. It said, “Once aware of natural light’s medical necessity to Ekstrand, the school district was obligated to provide Ekstrand’s specifically requested, medically necessary accommodation unless it would impose an undue hardship on the school district.”

The court said a jury would likely find “little hardship” in simply swapping classrooms. (Ekstrand v. School Dist. of Somerset, 7th Cir., 10/6/09)

2 lessons learned

1. Don’t stay in the dark. Make sure your managers are educated about the ADA because its coverage expanded this year. More ailments are considered disabilities than ever before. Ignoring ADA requests won’t make them go away.

2. Have a light bulb moment. If an accommodation request is reasonable, be smart enough to grant it rather than litigate over it. In this case, the court said the request was a “nonzero cost” … and what is more reasonable than free?


Mindy Chapman is an attorney and president of Mindy Chapman & Associates LLC. She is a master trainer, keynote speaker and co-author of the ABA book, Case Dismissed! Taking Your Harassment Prevention Training to Trial. Read her blog at

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