How a teacher's guide-dog training set the new line on paid versus unpaid leave
When two accommodations both work, who gets to choose? A federal appeals court just handed employers a clear answer.
On May 13, 2026, the Sixth Circuit ruled that Lakota Local School District in Ohio did not violate the Americans with Disabilities Act when it denied paid sick leave to a longtime art teacher with a serious disability. The district offered unpaid leave instead so she could attend guide-dog training, and that, the court said, was enough.
The teacher, Andrea Tumbleson, has Usher syndrome, a rare genetic disease that has gradually taken her hearing and vision. She has taught art at Lakota Plains Junior School for more than 20 years. According to the opinion, Rob Kramer, Lakota's Executive Director of Human Resources, described her teaching as excellent and her evaluations as consistently positive. The district has never disciplined her.
In early 2023, Tumbleson was matched with a guide dog, Henry, through Leader Dogs for the Blind in Rochester Hills, Michigan. To bring him home, she had to attend a three-week training course at the end of May 2023, which meant missing the close of the school year. She asked Lakota for 13 paid sick days. Kramer said no. The training, he explained, did not fall within the district's definition of personal illness under its sick-leave policy, Ohio law, or the collective-bargaining agreement. He approved unpaid leave as an ADA accommodation, along with...
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