Argenyi v. Creighton University

703 F.3d 441 (2013)

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Argenyi v. Creighton University

United States Court of Appeals for the Eighth Circuit
703 F.3d 441 (2013)

  • Written by Alexander Hager-DeMyer, JD

Facts

Michael Argenyi (plaintiff) had a significant hearing disability and required accommodations to succeed in school. Argenyi did not know sign language and relied on Communication Access Real-time Transcription (CART), a speech-to-text system, and a cued speech interpreter to effectively understand and participate in classes and labs. Argenyi was admitted to Creighton University (Creighton) (defendant) for medical school and requested accommodations for his coursework, including both CART and an interpreter. Creighton denied CART and interpreter services and provided only note-taking services and an FM radio system to boost sound to Argenyi’s hearing aid. Argenyi found that he had significant difficulty communicating and understanding speech in class and re-requested his original accommodations. Creighton continued to deny the request, and Argenyi took out thousands of dollars in private loans to pay for the services himself. Argenyi submitted five letters from his medical specialists, all of which emphasized Argenyi’s need for CART and interpreter services, but Creighton continued to deny Argenyi’s requests. Argenyi filed suit in district court, arguing that Creighton’s denial of requested accommodations violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act. Argenyi submitted an affidavit to the court detailing his difficulties during school, in both classes and clinical units where he interacted with actual patients. The district court granted summary judgment to Creighton, stating that Argenyi’s affidavit was self-serving and not supported by evidence. Argenyi appealed to the Eighth Circuit.

Rule of Law

Issue

Holding and Reasoning (Murphy, J.)

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