Tyndall v. National Education Centers

Mary Tyndall (plaintiff) taught at Kee Business College Campus (Kee), a school run by National Education Centers, Inc. (National) (defendant). Tyndall suffered from lupus erythematosus, an autoimmune condition causing joint pain, fatigue, and urinary and intestinal disorders. Dale Seay, the head of Kee’s Allied Health Department, hired Tyndall knowing about her condition. Tyndall was permitted to take sick leave, come in late, leave early, and take breaks during class. Seay and other teachers would cover Tyndall’s classes if Tyndall was not feeling well, and they frequently escorted her to the restroom and offered to drive her home. Tyndall began frequently missing work due to her own condition and that of her son, who suffered from a gastro-esophageal disease. Kee granted all of Tyndall’s requests for leave. After returning to work following one of her son’s surgeries, Tyndall informed Seay that she needed additional leave for an unknown amount of time to care for her son during his recovery. Seay told Tyndall that she could not have additional leave. Seay added that if Tyndall left again, she would miss the start of an instructional cycle for the third time, and teachers and students had complained about her absences. When Tyndall insisted on taking leave, Seay suggested that she resign and reapply when she was ready. Tyndall filed suit against Kee and National, claiming that her forced resignation violated the Americans with Disabilities Act (ADA) and state discrimination laws. The district court granted summary judgment for Kee and National on all counts. Tyndall appealed.