A teacher at a school for special needs students in Puerto Rico sued the employer and two administrators. She alleged they violated the Americans with Disabilities Act (ADA) and the Age Discrimination in Employment Act (ADEA) by taking her to a psychiatric hospital and placing her on an improvement plan.
By the teacher's own account, she suffered a "temporary nervous breakdown" in September 2015. The employer had told the teacher on multiple occasions since she started in 2005 that she needed to improve her performance in several areas. After a parent complained that the teacher had scared her child by yelling, the teacher's supervisor informed her she would be placed on a paid suspension while the school investigated the incident.
During the meeting with her supervisor, the teacher allegedly fell to the floor, started crying, and said that she wanted to kill herself. The school's clinical psychologist recommended contacting a mental health facility, which suggested bringing the teacher in for an evaluation.
According to the lawsuit, the head of the school told the teacher that he wanted to take her to a "crisis center" and that her "job depended on it." After meeting with a doctor, the teacher tried to leave the facility, which she claims she did not know was a psychiatric hospital. Hospital staff brought her back into the building and the head of the school signed an "Informed Consent for Psycho-Active Medication" form.
The head of the school and the woman's supervisor obtained a court order through Puerto Rico's Mental Health Act to keep her at the psychiatric hospital. She was treated and released on September 4, 2015. Following outpatient treatment, she was certified to return to work on September 21, 2015.
Based upon the lawsuit allegations, when she returned, the school placed her on a "Teacher Improvement Plan" because of the parental complaint and previous issues identified in her evaluations.
The district court ruled against the plaintiff in her lawsuit. The court found that she failed to show a prima facie case because she did not suffer adverse employment action. In addition, the school had a legitimate, non-discriminatory reason for her suspension with pay and the improvement plan, the court stated. The appellate court affirmed the district court's summary judgment against the teacher. It held that the school had reasonable basis for determining that a medical evaluation was "job-related and consistent with business necessity." Sandra Lopez-Lopez v. The Robinson School et al., Case No. 19-1386 (1st Cir, U.S. Ct. App) (May 11, 2020).