Chalk v. United States District Court Central District of California

Vincent Chalk (plaintiff), a teacher with the Orange County Department of Education (department) (defendant), had been working with hearing-impaired students for six years when he was hospitalized and diagnosed with AIDS. Chalk recovered and was cleared to work by both his personal doctor and the department’s physician. The department offered Chalk a nonclassroom role and told Chalk that it would sue to prevent him from teaching in a classroom if he refused. Chalk sought to return to teaching hearing-impaired students, and the department filed suit in county court. Chalk then filed his own lawsuit in federal district court pursuant to the Rehabilitation Act (act), seeking an injunction barring the department from keeping him out of classroom roles. Chalk presented substantial evidence seeking to establish that there was no apparent risk of HIV transmission were he to continue working in a classroom despite potential prolonged, nonsexual close contact with students. The district court found that Chalk had established that the probability of harm was minimal but ruled in favor of the department. The district court opined that the trauma to children and families over fears, however unsubstantiated, that they may catch HIV outweighed Chalk’s trauma from being prevented from reentering the classroom. Chalk appealed.