Angela Wood sued Independent School District No. 5 of Tulsa County, Oklahoma (Jenks Public Schools) in the United States District Court for the Northern District of Oklahoma, raising claims of disability discrimination and retaliation under the Americans with Disabilities Act (ADA). The defendant moved to dismiss plaintiff’s claims under Federal Rule of Civil Procedure 12(b)(6).
Factual Overview
Wood began working for Jenks Public Schools in 2005 as a middle school teacher. In 2011, she became the eighth-grade Team Leader, and in 2018, she became the Key Club Team Leader. In late 2017, Wood developed an infection resulting in significant hearing loss, which affected her ability to communicate with students. During the COVID-19 pandemic in 2020, Wood requested various accommodations for her hearing impairment, including assignment to a virtual teaching position and installation of plexiglass panels. While the school provided her with a hearing aid, the principal allegedly prevented the installation of plexiglass panels. Between April 2021 and May 2022, Wood continued seeking accommodations and applying for positions that would better accommodate her hearing loss. In October 2022, the principal removed Wood from her Team Leader position and allegedly berated her during a meeting about her accommodation requests. Wood resigned in March 2023 and filed an EEOC charge in June 2023.
Legal Analysis
Timeliness of Claims: The court rejected the defendant’s argument that Wood’s claims were untimely. The court found that Wood had alleged discrete discriminatory acts within the 300-day filing period, including the school’s failure to respond to accommodation requests made in October 2022 and February 2023.
Disability Discrimination: The court determined that Wood adequately alleged she had a disability under the ADA, as hearing loss constitutes a recognized impairment affecting a major life activity. The court found Wood sufficiently alleged she was qualified for her position and that the school failed to provide reasonable accommodations.
Retaliation: The court held that Wood plausibly alleged retaliation by showing she engaged in protected activity by requesting accommodations, suffered an adverse action when removed from her Team Leader position, and demonstrated a causal connection through temporal proximity and the principal’s alleged hostile comments about her accommodation requests.
The court denied the defendant’s motion to dismiss both Wood’s ADA discrimination and retaliation claims.
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