The New Jersey Supreme Court recently heard the case of a diabetic schoolteacher. The teacher experienced a hypoglycemic event and fainted in her classroom due to a late lunch period that led to her low blood sugar. She hit her head when fainting on a science laboratory table, causing severe and life-altering injuries.
The teacher then sued the Oakland Board of Education. She claimed that she repeatedly requested an earlier lunch period to manage her blood sugar levels better, but the school’s principal did not accommodate this request.
The school district moved for summary judgment, but two motion judges and an Appellate Court denied it. The district then sought for the teacher to prove that the injury led to her termination or demotion as grounds for its failure to accommodate a disability claim. The state’s high court ruled that the teacher did not need to prove demotion or termination under the Law Against Discrimination.
Exclusive remedy addressed
The school district also argued that the teacher could not file a lawsuit because she received worker’s compensation. While each case is different, worker’s compensation often has an exclusive remedy provision as part of its benefits. The lawsuit was able to proceed because the court ruled that an exclusive remedy did not apply to the principal’s failure to accommodate a preexisting condition.
Cases are seldom straightforward
This case is one more example of how different laws may apply to the same case. It can lead to different and sometimes competing conclusions that the courts must untangle.