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Ekstrand v. Sch. Dist. of Somerset, 7th Cir., No. 09-1853, Oct. 6, 2009

Articles Discussing Case:

Disabled employees must provide corroborating evidence of non-obvious, medically necessary accommodations.

Ogletree Deakins • October 26, 2009
Under the Americans with Disabilities Act, employers and employees are required to engage in an interactive process with respect to a disabled employee’s request for a reasonable accommodation. In cases of psychological disability - depression, for example - necessary accommodations may be non-obvious to the employer. In those cases, courts have held that in order to trigger an employer’s obligation to provide accommodation, a disabled employee must make the employer aware of any non-obvious, medically necessary accommodations by supplying corroborating evidence, such as a doctor’s note or statement. Recently, the 7th U.S. Circuit Court of Appeals reversed a lower court’s dismissal of a case, and found that a school failed to engage in the required interactive process after a teacher provided a doctor’s statement that linked the teacher’s Seasonal Affective Disorder depression to the lack of windows in her classroom.
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