Bahl v. County of Ramsey, et al, No. 11-2869 (8th Cir. 2012)
Annotate this CasePlaintiff appealed the district court's order granting the City of St. Paul's motion for summary judgment and dismissing his disability discrimination claims brought against the City under the anti-discrimination provisions of the Americans with Disabilities Act (ADA), 42 U.S.C. 12132; Section 504 of the Rehabilitation Act of 1973 (Rehabilitation Act), 29 U.S.C. 794; the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.12, as well as his claim for negligence. The court affirmed the district court's entry of summary judgment in favor of the City on plaintiff's claims regarding the traffic stop and plaintiff's claims regarding the statement of charges. Because a reasonable jury could conclude that a public service had been initiated and was stopped due to plaintiff's disability, the court reversed and remanded for further proceedings on the post-arrest claim. The court reversed the district court's grant of summary judgment on the City's request for vicarious official liability with respect to the post-arrest interview. Finally, the court affirmed the district court's grant of summary judgment on the negligence per se claim.
Court Description: Civil case - Civil rights. Event if the Americans with Disabilities Act applied to a traffic stop, the district court did not err in concluding that under the exigencies of the traffic stop, the police officer who made the stop was not required to honor Bahl's request to communicate by writing; giving Bahl the benefit of all reasonable inferences, no reasonable jury could conclude that the written charge statement he received did not provide him with meaningful access to the service of being notified of the reason for his arrest; further, at that time, written communication was the only auxiliary aid Bahl requested, and the record showed he understood the statement; however, Bahl's post-arrest interview was a service or activity covered by the ADA, and a reasonable jury could find that a public service had been initiated and stopped due to Bahl's disability; the district court erred in granting the City summary judgment on Bahl's claim under the Minnesota Human Rights Act as the City was not entitled to vicarious official immunity as a question existed as to whether the City should be liable for failing to develop and implement an adequate policy for communication-impaired individuals; failure to provide an interpreter to communicate the reasons for Bahl's detention and arrest did not violate the City's duties under Minn. Stat. Sec. 611.32. Judge Murphy, Concurring. Judge Gruender, Concurring.
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