When an elementary-school teacher in Wisconsin was transferred several years ago to a classroom without any natural light, she balked.
School officials ignored her.
But a U.S. appeals court recently ruled that the school district had violated the Americans with Disabilities Act for failing to move her back to a classroom with windows.
The teacher suffered from seasonal affective disorder, known as SAD, an extreme form of seasonal mood swings associated with depression and thought to be triggered by a lack of sunlight.
“Sometimes employers are not aware of something like SAD and the implications it has under the disabilities act,” said Jim Thomas, partner and employment-law expert with the Pittsburgh office of Pepper Hamilton LLP. “This is not something that should be ignored. It should be taken seriously.”
SAD is a debilitating form of the common winter blues. Symptoms can include depression, mood swings, lack of energy, increased need for sleep, difficulty concentrating, exaggerated weight gain and thoughts of suicide.
While the ailment often is triggered by the changing seasons, people who work long hours inside buildings with few windows may experience symptoms year-round, Thomas said.
Accommodations an employer may have to make may include relocating the employee to an area with more daylight; placing a light box in the workplace that mimics natural light; permitting extended breaks outdoors or moving a person off the night shift.
An employee also might be entitled to up to 12 weeks leave for treatment under the Family and Medical Leave Act.
An ailment is considered a disability under the disabilities act if it impairs a major life activity, such as thinking, sleeping, speaking, learning, eating or performing manual tasks, Thomas said.
Still, if the impairment does not affect essential job functions, the employee would not be covered under the act, he said.
“Let’s say, for example, I have some type of condition that substantially impairs my ability to bend. If my job doesn’t require me to bend, then obviously there is no need for any accommodation.”
That said, SAD can be a serious medical condition.
“Before brushing off an employee who complains of SAD,” Thomas said, “employers should consider whether the employee … has a disability protected by law.”
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