I love these odd cases – like the one-armed man who wanted to be an “unarmed” security guard, about which I blogged previously. Here’s another one that tickled my funny bone – the teacher with pedophobia, which is a debilitating fear of children! (Let’s just absorb the irony of that for a moment, shall we?)
OK, to be fair, the teacher feared younger children, but was fine with teaching older children – which was the issue in the case of Waltherr-Willard v. Mariemont City Schools. The teacher, whose diagnosis of pedophobia had previously been confirmed for school officials by a doctor, taught all levels of French and introductory Spanish to high school students. The high school decided to move all of its French courses online, which meant that a French teacher was no longer needed. With the teacher’s (self-proclaimed “enthusiastic”) agreement, she was transferred to the middle school for the next school year.
After six months, the teacher asked to be transferred back to the high school, stating that her talents were being “underutilized” and that another year at the middle school would be detrimental to her health. (As the parent of two crazy teenagers, I agree that prolonged interaction with this age group can be very detrimental to anyone’s mental health!!) The school district superintendent told her that there were no openings at the high school because there was already a Spanish teacher there. The teacher retired, and then sued the school district for failing to accommodate her disability of pedophobia, among other things.
The district court granted summary judgment for the school district, finding that her claims were without merit. The U.S. Court of Appeals for the 6th Circuit agreed. With regard to the failure to accommodate claim, the Court noted that the Americans with Disabilities Act requires an employer to accommodate an employee’s disability, but it does not require “unreasonable accommodations.” Requiring the employer to create a new job or to displace a current incumbent in a job is not reasonable as a matter of law, which I am sure you will be happy to know!