Back-to-School Hiring: Fifth Circuit Affirms that Classroom Supervision is an Essential Function Under the ADA

As schools prepare for the upcoming academic year and continue summer hiring, a decision from the United States Court of Appeals for the Fifth Circuit offers guidance on how educational institutions should review essential job functions and evaluate accommodation requests under the Americans with Disabilities Act (ADA).

In a pivotal legal decision, the United States Court of Appeals for the Fifth Circuit affirmed summary judgment in favor of a Texas school district in Kakoolaki v. Galveston Independent School District on April 2, 2025, holding that a legally blind applicant for a teaching position was not a “qualified individual” under the Americans with Disabilities Act (ADA) because she could not perform the essential functions of her job with or without reasonable accommodation. The court ruled that the applicant could not demonstrate her ability to supervise students both in the classroom and during passing periods.

This ruling provides valuable insights for both private and independent schools as they navigate the process of implementing reasonable accommodations and defining essential job functions within teaching roles. The decision is particularly relevant as schools finalize staffing in advance of the new school year.

Legally Blind Applicant Sought Teaching Position

Suzonne Kakoolaki, who suffers from cone dystrophy that renders her legally blind, applied for a sixth-grade social studies teaching position with the Galveston Independent School District (GISD). During her initial virtual interview, Kakoolaki received a conditional job offer contingent upon a successful background and reference checks. However, after voluntarily disclosing her visual impairment, GISD officials called her back for additional interviews.

Kakoolaki is legally blind and cannot identify faces or read facial expressions. She can, however, see silhouettes of persons and objects. She typically uses a cane and guide dog to help her walk. Although Kakoolaki cannot read standard print, technological advances have made it possible for her to read emails and other documents when magnified.

Following her disclosure, Kakoolaki participated in two more interviews. During the second interview, she addressed the limitations imposed by her disability. However, lingering questions remained, prompting a third interview. This final interview was structured as a “lecture,” where school officials outlined classroom expectations and reviewed the job description, which emphasized the importance of managing student behavior and ensuring safety.

Despite Kakoolaki's assurances, GISD ultimately hired another candidate. Kakoolaki responded by filing a lawsuit, alleging disability discrimination and failure to accommodate under the ADA. She argued that with reasonable accommodations, such as a full-time classroom aide and reassignment of hallway supervision duties, she could perform the essential functions of the teaching position.

Judicial Rationale and Behavior Management

The district court concluded that Kakoolaki was not a “qualified individual” under the ADA because she could not perform the essential functions of the teaching position. The ADA requires that an individual must be able to perform the essential functions of a job, with or without accommodation, to be considered “qualified.” As described by GISD, the job responsibilities of a social studies teacher include, in part, “[m]anag[ing] student behavior” and “[taking] all necessary and reasonable precautions to protect students, equipment, materials, and facilities.”

During her deposition, Kakoolaki admitted, under oath, that she could not perform these classroom management tasks alone. Due to her poor vision, she could not determine what exactly students were doing in the classroom. Kakoolaki readily acknowledged that, in a live classroom setting, she was unable to determine whether a student possessed a weapon, glanced at a cell phone, was cheating, or was otherwise misbehaving. The court determined that direct supervision of students is a fundamental aspect of teaching and Kakoolaki was unable to fulfill this critical duty.

The focus then shifted to evaluating whether she could perform these tasks with a reasonable accommodation. Kakoolaki proffered two accommodations for the supervisory duty she could not perform. Kakoolaki first requested a full-time classroom aide and, second, assistance from neighboring hallway teachers to help alert her to non-audible behavioral violations. In evaluating Kakoolaki’s proposed accommodations, the court found that having a teacher’s aide present in the classroom was not reasonable, as it would transfer essential teaching responsibilities to another person. The ADA does not permit the removal of fundamental job functions as a form of accommodation.

Additionally, Kakoolaki suggested using video recordings to monitor classroom behavior, which the court dismissed, emphasizing that addressing student issues requires immediate, real-time intervention. Since Kakoolaki was unable to propose a reasonable accommodation that would enable her to effectively monitor her classroom, the court concluded that she did not satisfy the ADA’s requirements and, therefore, could not prove her claims.

On appeal, the Fifth Circuit upheld the district court’s decision, concurring with the determination that Kakoolaki was unable to fulfill the essential functions of the teaching position, even with her proposed accommodations. The appellate court highlighted that the ADA does not obligate employers to eliminate or reassign essential job functions. And, by her own admission, Kakoolaki acknowledged that she could not directly supervise the students on her own.

Key Takeaways for Educational Institutions

This decision offers several important lessons for educational institutions navigating reasonable accommodation obligations under the ADA:

1. Engage in the Interactive Process: Schools must engage in an interactive process with applicants and employees who disclose disabilities to determine whether a reasonable accommodation would allow the applicant or employee to perform the essential functions of the position. This process should include thoughtful consideration of the individual’s proposed accommodations balanced against the practical realities of the school environment, operational impact and available resources. While some accommodations—such as assigning additional staff to perform essential duties—may be inherently unreasonable because they fundamentally alter the position, most accommodation requests require a careful, individualized, case‑by‑case analysis.
2. Avoid Disparaging Interview Questions:  The court emphasized that asking an applicant how she would “hide” her disability constituted direct evidence of discrimination. Schools should ensure that interviewers are trained on ADA compliance and understand which questions are legally appropriate to ask during interviews.
3. Clarify Essential Job Functions: Classroom management, including real‑time student supervision, is an essential function of teaching. Schools should regularly review and update job descriptions to ensure that essential functions accurately reflect the position’s actual requirements. Clear, well‑defined job descriptions help distinguish essential duties from marginal ones and promote consistency in hiring decisions by providing an objective framework for evaluating applicants. This clarity, in turn, helps reduce the risk of discrimination claims by grounding employment decisions in legitimate, job‑related criteria.

Please contact Erin Malone, Helen J. Jay or any member of Phelps’ Labor and Employment or Education teams with questions or for advice and guidance.