Narrative Opinion Summary
In this case, a former student of Lincoln College filed a complaint alleging violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973, citing a lack of reasonable accommodation for her auditory processing disorder. The court addressed the Defendant's Motion for Summary Judgment on multiple counts of the Amended Complaint. It granted summary judgment for the ADA claims, noting that injunctive relief under Title III was moot due to the Plaintiff's departure from the college. However, for the Rehabilitation Act claim, the court found a genuine issue of material fact regarding the Plaintiff's disability status, denying summary judgment. The Plaintiff claimed substantial limitation in major life activities, supported by evidence of academic struggles and the need for accommodations. The breach-of-contract claim failed due to lack of consideration, while the intentional infliction of emotional distress claim was dismissed, as the conduct in question fell outside the scope of employment. The court emphasized that a genuine issue of material fact regarding reasonable accommodations and deliberate indifference under the Rehabilitation Act warranted further proceedings. The Defendant's Motion for Summary Judgment was thus granted in part and denied in part.
Legal Issues Addressed
ADA Definition of Disability - ADA Amendments Act of 2008subscribe to see similar legal issues
Application: The ADAA's broadened definition of disability was applied, considering the Plaintiff's auditory processing disorder as potentially substantially limiting major life activities.
Reasoning: The ADAA emphasizes broad coverage and states that the interpretation of 'substantially limits' should align with its findings and purposes.
Americans with Disabilities Act (ADA) - Injunctive Reliefsubscribe to see similar legal issues
Application: The court determined that injunctive relief under Title III of the ADA was moot because the Plaintiff no longer attended the college and had no intention of returning.
Reasoning: The ADA claim was deemed moot since the Plaintiff had left Lincoln College and showed no intention to return.
Breach of Contract - Considerationsubscribe to see similar legal issues
Application: The court found no valid consideration for the alleged contract terms, granting summary judgment due to the absence of enforceable agreement.
Reasoning: The email exchange analyzed lacks evidence of consideration supporting any agreement.
Intentional Infliction of Emotional Distress - Scope of Employmentsubscribe to see similar legal issues
Application: The Plaintiff's claim for IIED was dismissed as the alleged conduct by an employee fell outside the scope of employment, negating vicarious liability.
Reasoning: The Plaintiff's IIED claim cannot be substantiated based on Mr. Carta's alleged conduct.
Rehabilitation Act - Deliberate Indifferencesubscribe to see similar legal issues
Application: The Plaintiff must demonstrate deliberate indifference by showing an official was aware of discrimination and failed to respond, which was disputed in this case.
Reasoning: To establish deliberate indifference, Plaintiff must show that an official with the authority to address discrimination was aware of it and failed to respond adequately.
Rehabilitation Act - Genuine Issue of Material Factsubscribe to see similar legal issues
Application: The court found sufficient evidence to preclude summary judgment on the Rehabilitation Act claim, as the Plaintiff raised a genuine issue of material fact regarding her disability status.
Reasoning: The court finds that the Plaintiff has raised a genuine issue of material fact regarding her disability claim.
Summary Judgment - Standard of Reviewsubscribe to see similar legal issues
Application: The ruling emphasized that summary judgment is appropriate when there is no genuine issue of material fact, and the non-moving party fails to provide sufficient evidence for essential elements of their claims.
Reasoning: Summary judgment is appropriate when there is no genuine issue of material fact, and the non-moving party fails to provide sufficient evidence for essential elements of their claims.