Lowe v. Independent School District No. 1 of Logan County, Oklahoma

Terianne Lowe (plaintiff) worked for Independent School District No. 1 of Logan County, Oklahoma (the district) (defendant). Lowe had polio as a child and experienced ongoing difficulties with her legs. Lowe was certified to teach science, but she had worked for years as a high-school counselor because that was a sedentary position that did not require any accommodations for her postpolio disability. In 2005, the district superintendent decided to reassign Lowe as a classroom teacher for the 2006-07 school year. The only science-teacher opening at the high school was a physical-science class in a very small classroom that could not accommodate a walker or wheelchair. Lowe realized that she would likely be reassigned to teach in the small classroom and met with the head of the high school’s science department to discuss the accommodations that Lowe would need to teach in that room. Before the end of the 2005-06 school year, Lowe presented a list of accommodations to the school principal and district officials. Lowe received a message from the principal that no accommodations would be made and then heard nothing else from the district for four months. In August 2006, two weeks before school started, an official from the Oklahoma Education Association set up a meeting with Lowe and district officials to discuss Lowe’s requested accommodations. The district superintendent did not prepare for the meeting and had not reviewed Lowe’s requested accommodations in advance. The meeting attendees disagreed about whether Lowe was told during the meeting that no accommodation would be made. However, Lowe was dissatisfied with the district’s response and resigned two days later. Lowe then sued the district for failure to reasonably accommodate her disability in violation of the Americans with Disabilities Act (ADA). The district court granted summary judgment for the district, and Lowe appealed.