Aikins v. St. Helena Hospital

Elaine Aikins (plaintiff), a deaf woman, accompanied her husband, Harvey Aikins, to St. Helena Hospital (the hospital) (defendant). Dr. James Lies (defendant), an independent contractor, treated Harvey for a massive cardiac arrest. The hospital failed to provide a sign-language interpreter or any other auxiliary aid (i.e., a service or device that enables persons with impaired sensory, manual, or speaking skills to participate in programs or activities). Because Lies did not ask Elaine about the timing of the paramedics’ response, Lies performed a pointless emergency surgery on Harvey. Three days after Harvey’s heart attack, Elaine’s stepdaughter facilitated the first direct conversation between Lies and Elaine, during which Elaine requested that Harvey be removed from life support. Harvey died two days later. Elaine sued the hospital and Lies in federal district court, alleging that Lies’s inability to communicate with her had violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA). Both the hospital and Lies filed motions to dismiss the case or, in the alternative, motions for summary judgment. Lies argued that the ADA did not apply to him because he was an independent contractor. The hospital argued in part that retaining sign-language interpreters would present an undue burden. The district court considered the hospital’s and Lies’s motions.