Crowder v. Kitagawa
United States Court of Appeals for the Ninth Circuit
81 F.3d 1480 (1996)
- Written by Alexander Hager-DeMyer, JD
Facts
The State of Hawaii (defendant) had a quarantine law designed to prevent the spread of rabies on the islands. The law required a 120-day quarantine for dogs, cats, and other animals, including guide dogs. A process existed for disabled individuals to have limited access to guide dogs for three days each week during the quarantine period, but during the three days, the dogs were forbidden to have contact with other humans or animals. The policy effectively denied disabled individuals from using their service animals for extended time frames. Guide-dog users (plaintiffs) filed suit in federal district court, alleging that the policy violated the Americans with Disabilities Act (ADA). As part of the initial court proceedings, the guide-dog users suggested modifications to the policy to better accommodate guide dogs, including vaccination requirements. However, because the vaccination requirements had previously been debated by the state legislature but not implemented, the district court concluded that it could not rule on whether vaccination was a reasonable modification under the ADA. The district court granted summary judgment for Hawaii, finding that the policy did not violate the ADA because the guide-dog users were not denied any public benefits or services. The guide-dog users appealed the case to the Ninth Circuit.
Rule of Law
Issue
Holding and Reasoning (Thompson, J.)
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