Eleventh Circuit: An Employee’s Mental Health Issues Can Lead to Termination

In May, the Eleventh Circuit Court of Appeals heard a case involving termination and an employee’s mental health issues. Specifically, in Todd v. Fayette County School District, judges agreed with the decision to end a mentally ill teacher’s employment. Likewise, mental health issues have been popping up in other aspects of the government. Earlier, in April, the U.S. Department of Labor selected seven states to participate in a new mental health initiative.

Background of Case

Previously, the plaintiff suffered from suicidal thoughts and was diagnosed with major depressive disorder and anxiety. Moreover, the school district was aware of the teacher’s struggles, as she informed the school principal. Afterward, the principal encouraged the plaintiff to seek professional help and receive a formal diagnosis. However, the teacher’s depression worsened, and coworkers reported that the teacher had threatened to kill herself and her son.  Also, a coworker said that the plaintiff consumed an excessive amount of Xanax while at work in their presence. Consequently, the teacher was involuntarily committed to a psychiatric facility. Eventually, a doctor provided a work release stating that the plaintiff did not “pose a threat” to herself or others. The school, however, continued its investigation into the employee’s mental health issues. The plaintiff objected to the inquiry believing it a violation of the Americans with Disabilities Act (ADA). After a few days, the school informed the plaintiff that the district would terminate her employment if she did not resign. Nevertheless, the plaintiff refused to resign and requested leave under the Family Medical Leave Act (FMLA). The school district granted her request. While the plaintiff was on leave, coworkers informed the district that the plaintiff had made threats against school administrators. Shortly after that, the school district did not renew the plaintiff’s employment contract. Following the termination, the plaintiff sued, alleging unlawful discrimination in violation of the ADA and Rehabilitation Act. Also, the plaintiff claimed FMLA interference. During the original trial, the school district contended that the termination stemmed from the threats against the administration. The termination did not originate from the employee’s mental health issues. Although the plaintiff denied any threats, the trial court granted judgment in the school district’s favor. After that ruling, the plaintiff appealed.

Summary of Eleventh Circuit Decision

Because of the appeal, the Eleventh Circuit only had one issue in front of them. Basically, was the previous judgment legal since the alleged threats made resulted from mental health issues. In summary, the court found that the school district met its burden in explaining a legitimate, nondiscriminatory reason for termination. For instance, while the employee’s behavior stemmed from depression, the termination was not because of mental health issues. Instead, the termination was due to the employee’s conduct, which included threats against coworkers.

Employer Takeaways

Although this court decision is favorable for employers, businesses should realize that each wrongful termination case contains its own merits. Before taking any adverse employment actions on employees in protected categories, employers should consult with appropriate legal counsel.