In McQuillan v. Springfield Public School District 186, the United States District Court for the Central District of Illinois granted summary judgment in favor of the Springfield Public School District 186, thereby rejecting allegations that it was in violation of the Americans with Disabilities Act (“ADA”) or the Rehabilitation Act of 1973 (“Rehabilitation Act”).
The plaintiff, a parent who suffers from cerebral palsy and uses a wheelchair, filed a lawsuit against the District, alleging that one of its high schools, Lanphier High School (“LHS”), failed to comply with the requirements of the ADA and the Rehabilitation Act. The parent claimed that because of the District’s alleged violations, he was unable to participate in a number of programs with his son, who is a student at LHS.
A few months after the parent filed his lawsuit, the Department of Justice (“DOJ”) assessed LHS and listed a number of items that needed improvement. In response to the DOJ’s assessment, the District made more than twenty modifications.
Despite these modifications, the parent amended his complaint, alleging that the District was still not in compliance with the ADA. Specifically, the parent alleged that (1) the accessible bathrooms remained unsatisfactory, (2) LHS did not provide proper wheelchair seating in the basketball gymnasium, and (3) LHS did not have proper signage on the exterior doors of the school to direct those with disabilities to the nearest accessible entrance. The District moved for summary judgment in its favor, and the court granted the District’s motion on all grounds.
With regard to the accessibility of LHS’s bathrooms, the parent claimed the bathrooms lacked signs outside of the inaccessible bathrooms directing individuals to accessible bathrooms and the doors required twice the amount of pressure to open as is legally permitted. The parent, however, failed to present any evidence supporting these allegations, whereas the District presented the court with pictures of the existing signs and pressure tests of the doors indicating otherwise. With respect to proper wheelchair seating in the basketball gymnasium, the court found that seating options provided by the District were substantially equivalent to all other seating options. Furthermore, because the District had already placed proper signs at all exterior doors by the time the court heard the summary judgment motion, the court held that the parent’s last issue was irrelevant.
Ultimately, the court ruled in favor of the District for two key reasons. First, and most important, the parent’s claims were either wholly unsupported or directly contradicted by evidence provided by the District. Second, the District implemented over twenty modifications after the DOJ’s assessment, demonstrating that it took any and all ADA-compliance issues seriously. School districts should ensure that their facilities comply with ADA requirements and implement any modifications necessary to remain compliant.