A concussion, a denied leave, and what a principal allegedly said at a staff meeting
A federal judge has cleared most of a DC teacher's disability and retaliation claims – and the ruling is a warning to HR.
In a decision issued May 11, 2026, US Magistrate Judge G. Michael Harvey allowed Star Dehaarte's lawsuit against the District of Columbia to move forward on her core claims, dismissing only one slice of her tort case. The opinion is a useful read for HR teams handling leave, medical information, and post-injury performance reviews.
Dehaarte worked as a physical education teacher at Browne Educational Campus, part of DC Public Schools. She says she slipped on ice outside her school on January 8, 2025, briefly lost consciousness, and was taken to the hospital by ambulance. Five days later, she told administrators – including Principal Shawna Dix – that she had a severe concussion and could not return without physician clearance. She asked for medical leave and gave the school medical documentation when asked.
What allegedly happened next is the part HR will want to mark up. According to the filings, Dix told a staff meeting that same day that Dehaarte was not really injured and was attending women's health appointments. Dehaarte alleges Dix later shared her private medical information with coworkers, including male staff members who, in the complaint's words, "had no legitimate work-related need to know," and specifically said she was at "OB-GYN appointments."
Dehaarte applied for FMLA leave on February 7, 2025. Her federal FMLA, DC FMLA, and DCPS extended leave requests were all denied on April 29, 2025. Before the school year ended, she got a negative IMPACT teaching evaluation. On May 9, 2025, she was told her position was being "excessed." She was separated from DCPS in August 2025.
The District moved to dismiss most of her claims and to win partial summary judgment on the rest. The court mostly said no.
On the ADA, the District argued there is no standalone cause of action for disclosing confidential medical information. Judge Harvey disagreed. He found Dehaarte plausibly alleged that her employer obtained her medical records through a job-related inquiry, disclosed them, and caused her real injury – shame and embarrassment – which the court said is enough under 42 U.S.C. § 12112(d).
The court also rejected the argument that a concussion is too short-term to be a disability. Citing the ADA Amendments Act of 2008, Harvey wrote that Congress threw out the old "permanent or long term" rule for the actual-disability prong. Dehaarte's claim that her concussion substantially limits working, concentrating, standing, and walking was enough to survive.
Her Rehabilitation Act claim cleared the same bar. So did her reasonable-accommodation theory: the court said a request for medical leave can, in some circumstances, qualify as a request for accommodation, and the District had not seriously briefed otherwise.
The FMLA retaliation claim also survived. The court let stand, for now, the link between her leave request and the negative evaluation and excessing that followed.
The District did win one piece. Dehaarte's negligent supervision and intentional infliction of emotional distress claims were partially dismissed because she did not give the written notice DC law requires for unliquidated damages claims against the city. Those torts survive only to the extent she seeks declaratory relief and lost benefits, including lost wages.
For HR, the takeaways are blunt. Medical information collected to support a leave request stays confidential. Sharing it at a staff meeting - in the version of events the court must accept at this stage - is the kind of move that builds an ADA case. Short-term injuries can be disabilities under the post-2008 ADA, so writing off a concussion as "not real" is working from outdated law. Leave requests should be run through both FMLA and ADA filters. And the timing of evaluations and position changes after a protected request will be scrutinized – by lawyers, and by courts.
The case continues on the surviving counts. The allegations have not been tested at trial, and no court has ruled on the merits.
