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Center for Public Representation

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Center for Public Representation

A Public Interest Law Firm Dedicated to Serving Individuals
with Disabilities for More Than 30 Years

ADA

For over two decades before the enactment of the ADA, the Center filed several class action cases to end the unnecessary institutionalization of persons with disabilities.  Since the passage of the ADA, the Center has initiated litigation to enforce its integration mandate on behalf of children, persons with psychiatric disabilities in state hospitals, persons with intellectual disabilities in public and private ICF/MRs and nursing facilities, persons with brain injuries, and adolescents in juvenile justice facilities.  It has also filed cases to expand access to community activities and opportunities, including voting, public accommodations, insurance coverage, medical care, and recreational services.
 
Documents and pleadings which may be helpful to attorneys litigating or considering the litigation of disability law related cases are available by following the links below.

Disability discrimination in prisons, jails and juvenile correctional facilities:
The Center has brought litigation against prisons and juvenile correctional facilities challenging the inappropriate segregation and isolation of inmates with mental illness and their resulting discriminatory exclusion from programs and activities under the ADA and § 504.  Copies of the complaints in DLC v. Mass. Dept. of Corrections (adults) and Michigan P&A v. Caruso (juveniles) are available below.  The Center also authored an amicus brief in Pennsylvania Dept. of Corrections v. Yeskey, 524 U.S. 206 (1998), the case that held that the ADA applies to state prisons.  Also linked below is a guide which provides references and citations to ADA cases challenging conditions in prisons and jails.
Michigan P&A v. Caruso, complaint, Civ. No. 5:05-CV-0128 (W.D. Mich.)
Disability Law Ctr v. Mass. Dept. of Correction, complaint, Civ. No. 07-10463 (D.Mass.)
Pennsylvania Dept. of Corrections v. Yeskey, Supreme Court amicus brief
A guide to litigation under the ADA in prisons and jails 1/23/2000

Discrimination on the basis of disability (mental illness): Hargrave v. Vermont
The Center authored an amicus brief in a case challenging Vermont's mental health advance directive law which created an exception for individuals with mental illness who were involuntarily committed and who the State wanted to medicate with psychotropic drugs.  The brief addressed claims that the exception constituted discrimination on the basis of disability in violation of the ADA and Section 504. Below are the amicus brief and the 2d Circuit decision affirming the district court decision which held that the exception constituted disability discrimination.
Hargrave v. Vermont, amici brief, 8/1/2002
Hargrave v. Vermont, 2d Circuit decision, 340 F.3d 27 (2d Cir. 2003)

Enforcing the Integration Mandate for Institutionalized Persons with Mental Illness The Center has filed a new Olmstead case in New Hampshire, Lynn E. v. Lynch.  Documents to date, follow below.  Read more information on the Mental Health page.
Lynn E. v. Lynch Complaint
Lynn E. v. Lynch Press Release
Lynn E. v. Lynch Fact Sheet
Lynn E. v. Lynch Letter to Assistant Attorney General Perez, December 6, 2011
Lynn E. v. Lynch Letter to Attorney General Delaney, December 9, 2011
Lynn E. v. Lynch Plaintiffs' Demand Letter, sent November 2, 2010
Lynn E. v. Lynch DOJ Findings Letter, issued April 7, 2011

Enforcing the Integration Mandate in Employment: Lane v. Kitzhaber The Center, together with the Oregon P&A and the firms of Miller Nash LLP and Perkins Coie LLP, filed the first class action in the nation that challenges sheltered workshops as a violation of the ADA's integration mandate.  Read more about Integrated Employment.

Disability discrimination in insurance underwriting:
This amici brief rebuts the insurance industry's defense to a disability discrimination claim that it is too expensive to provide parity to individuals with psychiatric disabilities in disability insurance.  The case settled favorably to the plaintiff following oral argument in the Massachusetts Supreme Judicial Court. 
Currie v. Group Insurance Commission, et al amici brief, 10/20/2002

Disability discrimination in parole decisions: 
A discussion of the extent to which the ADA may be helpful to prisoners in parole decisions
The ADA and parole decisions, 6/1/1999

Requiring accommodations to a victim/witness with aphasia: In re McDonough
CPR has filed an amici brief on behalf of numerous national and state organizations in support of the appeal of a victim with a communication disability who was denied the right to testify against a criminal defendant whom she said sexually abused her in her nursing facility. The amici argued, and the Supreme Judicial Court essentially agreed, that the trial court should have considered whether she could have testified with reasonable accommodations. The case was originally captioned Commonwealth v. Agana. Below are the amicus brief and decision.
In re McDonough, amici brief
In re McDonough, decision, 457 Mass. 512 (2010)

ADA Class Certifications
This document is a list of ADA cases challenging unnecessary institutionalization in which a class has been certified.
Class Certification Decisions

Disability discrimination in hospital emergency departments:
The Center has challenged discriminatory hospital emergency room practices which require individuals with mental illness to undergo strip searches as a condition of receiving treatment.  Below is the complaint in Sampson v. Beth Israel Hospital, a case which settled after discovery and shortly before trial.
Sampson v. Beth Israel Deaconess Med. Ctr, 2nd amended complaint, Civ. No. 06-10973 DPW (D. Mass.)

Disability discrimination in nursing facilities and other long term care facilities:
The Center has challenged the inappropriate institutionalization of individuals with developmental disabilities in nursing facilities and of individuals with acquired brain injury in long term care facilities based upon the integration mandate of the ADA and § 504, as well as other provisions of those statutes.  The nursing facility cases also raise claims under the Nursing Home Reform Amendments to the Medicaid Act and other Medicaid Act provisions.  The Rolland case (nursing facilities) settled, but not before generating a number of decisions focusing on the NHRA issues (see Nursing Facilities section for these documents).  Below are the complaints in two nursing facility cases (Rolland and Steward) and one acquired brain injury case (Hutchinson), as well as the settlement in Hutchinson.
Rolland v. Cellucci, amended complaint, Civ. No. 98-30208-KPN (D. Mass.)
Steward v. Perry, complaint, Civ. No. 5:10-cv-1025-OG (W.D. Tex)
Steward v. Perry, intervenor's complaint of United States, Civ. No. 5:10-cv-1025-OG
Hutchinson v. Patrick, Civ. No. 07-CV-30084-MAP (D. Mass.)
Hutchinson v. Patrick, amended complaint, part 2 of 2, Civ. No. 07-CV-30084-MAP
Hutchinson v. Patrick, settlement agreement, Civ. No. 07-CV-30084-MAP

The documents contained on this page and within this web site do  not constitute legal advice. Anyone engaged in legal action should  consult with an attorney. Attorneys should make their own independent  judgments. Local laws vary and the law may have changed since these  documents were written. Litigants should fully research any claims or  defenses before making them.

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Center for Public Representation
22 Green Street
Northampton, MA 01060
413-586-6024

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