Center for Independence of the Disabled, New York v. Metropolitan Transit Authority

The Metropolitan Transportation Authority (MTA) (defendant) designated approximately 123 of 472 subway stations in the New York City subway system as disabled-accessible. Only some stations had more than one elevator, and mobility-disabled subway riders claimed that there were routinely elevator outages at accessible stations, particularly at the busiest stations during peak times. Station elevators were equipped with electronic monitoring that remotely detected malfunctions and reported them to the New York City Transit Authority (NYCTA) (defendant). NYCTA’s control desk would dispatch maintenance to investigate. Once an outage was confirmed, control would open a work order and provide an estimated time for repair. The outage was then visible on MTA’s website along with suggestions for alternate accessible routes. Additionally, riders could sign up for text or email alerts regarding outages impacting specific elevators. In the stations themselves, electronic signs alerted to elevator outages, and signs on the elevators suggested alternate accessible routes. In the event of an outage, there were three main alternative transportation options, namely using other elevators if available, transferring to a different subway line at another accessible station, and back-riding, meaning going past the intended stop and taking another line back in the direction from which the rider came. Also, riders could use the bus system, which ran parallel to the subway system. A group of mobility-disabled individuals and nonprofit organizations (plaintiffs) filed a class-action suit against MTA and NYCTA, alleging violations of the Americans with Disabilities Act and the Rehabilitation Act based on a failure to provide reasonable accommodations. MTA and NYCTA argued that the various forms of outage notifications and transportation alternatives were sufficient to constitute reasonable accommodations. However, the mobility-disabled riders argued that the existing accommodations were inadequate because significant hardships resulted from notification delays and delays from using the transportation alternatives. They sought additional accommodations in the form of outage announcements on trains themselves, shuttles to nearby accessible stations during an outage, a policy of installing backup elevators, and training for subway employees to better assist riders during outages. MTA and NYCTA moved for summary judgment.