Bechtel v. East Pennsylvania School District
United States District Court for the Eastern District of Pennsylvania
1994 U.S. Dist. LEXIS 1327, 3 A.D. Cases (BNA) 200 (1994)
Bechtel (plaintiff) was a student preparing to attend Emmaus High School (school) in the East Pennsylvania School District (district) (defendant). Bechtel had spina bifida and used a wheelchair for mobility. Bechtel had attempted to use several of the school’s facilities, both for his own purposes and to attend his sister’s school events, and many of the facilities were not wheelchair accessible or usable. Bechtel expressed his dissatisfaction to the district regarding the school’s lack of accommodations for disabled students. Unrelatedly, the district began renovating the school and met with an architect to discuss plans. The architect advised the district about the legal requirements for accessibility and told the district that the changes would be relatively inexpensive to make. However, the district refused to make the accessibility renovations. Bechtel filed suit against the district in federal court, claiming discrimination under Title II of the Americans with Disabilities Act (ADA) and Pennsylvania state law. The district moved to dismiss, claiming that under the ADA and state law, Bechtel was required to exhaust his administrative remedies before his claim could be heard in court. The court dismissed Bechtel’s state-law claim, finding that Bechtel was required to file a complaint with the Department of Labor and Industry before commencing a civil suit. The court then addressed the ADA claim.
Rule of Law
Holding and Reasoning (Cahn, C.J.)
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