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Addressing Chronic Conditions

Payan v. Los Angeles Community College District


Payan v. Los Angeles Community College District (U.S. Court of Appeals, 9th Circuit, Aug. 24, 2021): Plaintiffs, including a nonprofit advocacy group and students enrolled at a Los Angeles Community College District (LACCD) campus, argued that LACCD systematically discriminated against blind students by failing to make learning materials accessible in violation of the Rehabilitation Act and Americans with Disabilities Act. The trial court agreed with plaintiffs, granting them damages, and permanently blocking LACCD’s allegedly discriminatory actions. On appeal, the 9th Circuit reversed the lower court’s decision, finding it had incorrectly limited the scope of the discrimination claims by only considering the claims as “disparate impact” discrimination claims to the exclusion of other theories, including the failure to make reasonable accommodations. Nonetheless, the 9th Circuit concluded that disparate impact disability discrimination claims may be enforced through a lawsuit. Read the full decision here.

View all cases in the Judicial Trends in Public Health – October 15, 2021.

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