Strife v. Aldine Independent School District

In the army, Alisha Strife (plaintiff) incurred physical injuries and was diagnosed with posttraumatic stress disorder (PTSD). After being medically discharged, Strife worked in human resources at Aldine Independent School District (AISD) (defendant). The Department of Veterans Affairs (VA) eventually classified Strife as 100 percent disabled by PTSD and partially disabled by physical injuries. Strife received a certified service dog, Inde, to help maintain her balance and mitigate severe PTSD symptoms. In August 2022, Strife requested that AISD allow Inde to join her at work. An interactive review process followed. Strife provided letters from her VA treatment provider and her psychologist attesting that Inde was invaluable. In November, the psychiatrist completed a questionnaire, identifying Inde as a reasonable accommodation that would allow Strife to overcome functional limitations. Ten days later, AISD told Strife she needed to submit to an examination by an AISD-affiliated physician. Strife hired legal counsel. Her lawyer contacted AISD regarding disability-law violations. AISD responded that it was entitled to engage in an interactive process to determine an appropriate accommodation and that a medical exam was part of that process. On January 6, Strife’s lawyer provided three letters affirming Strife’s disability and urging AISD to approve her accommodation request. The lawyer also submitted new VA examinations affirming that Inde was essential to prevent balance-related injuries. AISD questioned the examinations’ sufficiency. Strife then sued AISD, asserting claims including failure-to-accommodate, hostile-work-environment, disability-discrimination, and retaliation claims under the Americans with Disabilities Act (ADA). Shortly thereafter, in response to an email from Strife’s attorney stating that other accommodations would not be effective, AISD granted Strife’s requested accommodation. Strife persisted with her claims, focusing on AISD’s delay. The district court dismissed the failure-to-accommodate and hostile-work-environment claims and granted summary judgment in AISD’s favor on the disability-discrimination and retaliation claims. Strife appealed.