August 23, 2002
Disability Compliance Bulletin
SECTION: Vol. 24, No. 3
Case name: Young v. Central Square Central Sch. Dist., 24 NDLR 79 (N.D.N.Y. 2002).
Ruling: The U.S. District Court, Northern District of New York held that a school teacher with multiple sclerosis raised genuine issues of material fact with respect to whether the school district failed to accommodate her disability. The District Court further ruled that collateral estoppel did not bar the teacher from maintaining her ADA and Rehabilitation Act failure to accommodate claims against the district, even though the district had conducted a hearing to determine whether the teacher could perform the essential functions of her job. What it Means: Whether an employer has reasonably accommodated a worker with disabilities is a separate issue from whether the worker is able to perform the essential functions of her job. As long as the worker presents sufficient evidence to raise a genuine issue of material fact over whether the employer failed or refused to accommodate her, she will have her day in court. This is true regardless of whether the employer indicated the worker was not able to perform her essential job functions.
Summary: Elementary school teacher Kathleen Young alleged that Central Square Central School District violated Title I and the Rehabilitation Act by failing to reasonably accommodate her disability. After Young was diagnosed with multiple sclerosis, she notified the school district, which in turn acknowledged its duty to provide her with reasonable accommodations. Eventually, the district approved Young's transfer to a school closer to her home and hired a teacher's aide to assist her.
Shortly after her transfer, Young received a negative evaluation for perceived shortcomings in conducting full-class instruction. The Board of Education brought disciplinary charges against Young pursuant to the New York Education Law. The hearing panel determined that Young was unable to perform her job and terminated her employment. After unsuccessfully challenging the hearing panel's decision, Young filed this lawsuit against the district. The district moved for summary judgment, in part on the ground that the doctrine of collateral estoppel required dismissal of Young's lawsuit. The district also moved to disqualify Young's counsel.
Collateral estoppel did not bar Young from litigating the issue of whether the district discriminated against her by refusing or failing to provide her with reasonable accommodations which would enable her to perform the essential functions of her job. The hearing panel decided the issue of whether Young was able to perform the essential functions of her job without an accommodation, but did not address whether she could have performed her position with a reasonable accommodation.
Another reason Young's lawsuit survived the district's motion for summary judgment is because of the conflicting statements concerning the district's willingness to reasonably accommodate Young and participate in the interactive process in good faith.
Although the District Court denied the school district's motion for
summary judgment and motion to amend its answer to add the affirmative
of collateral estoppel, it granted its motion to disqualify Young's law
firm. One of the attorneys who works in the law firm representing Young
had previously represented the district when she worked at a former law
© Copyright 2002 LRP Publications