The Arc of Iowa v. Reynolds, No. 21-3268 (8th Cir. 2022)
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Plaintiffs, the Arc of Iowa and Iowa parents whose children have serious disabilities that place them at heightened risk of severe injury or death from COVID-19, filed suit to enjoin enforcement of Iowa's law prohibiting mask requirements in schools. The district court concluded that the law violated the Americans with Disabilities Act and Section 504 of the Rehabilitation Act, granting a preliminary injunction completely enjoining the law.
After determining that it has jurisdiction, the Eighth Circuit held that plaintiffs are entitled to a preliminary injunction because mask requirements are reasonable accommodations required by federal disability law to protect the rights of plaintiffs' children. However, the court concluded that the injunction imposed by the district court sweeps more broadly than necessary to remedy plaintiffs' injuries. Accordingly, the court vacated in part and remanded to allow the district court to enter a tailored injunction prohibiting defendants from preventing or delaying reasonable accommodations and ensures that plaintiffs' schools may provide such reasonable accommodations.
Court Description: [Benton, Author, with Kelly and Erickson, Circuit Judges] Civil case - Americans with Disabilities Act. Plaintiffs, a disability rights group and the parents of children with serious disabilities that placed them at heightened risk of severe injury or death from COVID-19, were entitled to a preliminary injunction enjoining enforcement of Iowa's law prohibiting mask requirements in schools; mask requirements are reasonable accommodations under the ADA and the Section 504 of the Rehabilitation Act required to protect the rights of plaintiffs' children; plaintiffs had standing to pursue the action because they established injuries fairly traceable to defendants' conduct and likely to be redressed by a favorable judicial decision; plaintiffs did not have to exhaust their claims under the Individuals with Disabilities Education Act, as its exhaustion requirement did not apply to their claims; however, the injunction sweeps too broadly, and the matter is remanded to the district court to enter a tailored injunction that prohibits defendants from preventing or delaying reasonable accommodation and ensures that plaintiffs' schools may provide such reasonable accommodation. Judge Erickson, dissenting. [ January 24, 2022 ]
The court issued a subsequent related opinion or order on May 16, 2022.
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