Zaneta Lightfoot, a teacher with sickle cell anemia, sued the Henry County School District under the Family and Medical Leave Act and the Americans with Disabilities Act. She alleged that school administrators disciplined her because of her medical leave, denied an accommodation that would have reduced painful walking, and later declined to renew her contract. The district court granted the School District summary judgment on the ADA claims and, after reconsideration, held that the District was an arm of Georgia protected by Eleventh Amendment immunity on the FMLA claim. The Eleventh Circuit reversed that immunity ruling. Applying the four-factor Manders analysis, it held that Georgia school districts are political subdivisions with substantial local control over teacher discipline, evaluation, funding, and judgments, rather than arms of the State. The court affirmed, however, the separate judgment against Lightfoot’s ADA-retaliation claim because the complaint pleaded retaliation based on a workplace complaint, not on requesting FMLA leave, and a plaintiff may not add a new factual theory through a summary-judgment brief. The case was remanded on the FMLA claim.