Corrigan v. Boston University, No. 23-1003 (1st Cir. 2024)
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The case involves Caitlin Corrigan, a graduate student at Boston University (BU), who sued the university under the Americans with Disabilities Act (ADA) for implementing a mandatory COVID-19 testing program. Corrigan claimed that due to a chronic medical condition, she could not comply with the program and that requiring her compliance would violate the ADA. BU rejected her proposed exemption, leading to her suspension for the fall semester. However, before the district court could reach the merits of Corrigan's claims, BU ended its mandatory testing program, leading the court to dismiss Corrigan's suit for lack of subject-matter jurisdiction, arguing that it had become moot.
BU moved to dismiss Corrigan's suit for lack of subject-matter jurisdiction, and the district court granted the motion, applying mootness principles. The court determined that since BU had ended its mandatory testing program, an order requiring BU to provide Corrigan with a reasonable accommodation to the program would have no effect. The court also found that Corrigan's claim was not inherently transitory and that BU was unlikely to subject Corrigan to mandatory testing again. The court held that the monetary relief that Corrigan sought was legally insufficient to support a claim of jurisdiction.
The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court concluded that the district court appropriately applied mootness principles to dismiss Corrigan's suit and that Corrigan had not shown that her case comes within an applicable exception to those mootness principles. The court rejected Corrigan's arguments that the district court misread the mootness exceptions, misconstrued the facts, and ignored the import of the ADA's scheme for providing prospective relief.
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