Brooklyn Center for Independence of the Disabled v. Metropolitan Transportation Authority, No. 20-1433 (2d Cir. 2021)
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The Second Circuit vacated the district court's grant of summary judgment in favor of defendants in an action brought by a certified class of individuals with disabilities, together with six disability-rights organizations, alleging that the failure to adequately maintain subway-station elevators violates the Americans with Disabilities Act (ADA), the Rehabilitation Act (RA), and the New York City Human Rights Law (NYCHRL).
As a preliminary matter, the court rejected the MTA's argument that this case is nonjusticiable, and the MTA's argument that the court must consider the accessibility of the transit system as a single unit that includes subways, buses and paratransit. The court concluded that there are genuine disputes of material fact as to whether frequent and inconvenient elevator outages deprive at least some passengers with disabilities of adequate access to the subway. However, the court explained that summary judgment would nonetheless be proper if it can be determined as a matter of law that reasonable accommodations are provided during those outages. Because the district court did not reach the issue of reasonable accommodations and did not sufficiently consider the NYCHRL claim, the court remanded for further proceedings.
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