Galloway v. Superior Court
United States District Court for the District of Columbia
816 F. Supp. 12 (1993)
Donald Galloway (plaintiff) reported for jury duty at the Superior Court of the District of Columbia (the Superior Court) (defendant). Superior Court personnel told Galloway that he was barred from serving as a juror because he was blind, and an official court policy excluded all blind people from jury service. Galloway sued the Superior Court in the United States District Court for the District of Columbia, alleging that the Superior Court’s policy of systemically excluding blind people as jurors violated both the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA). Galloway sought declaratory and injunctive relief invalidating the Superior Court’s policy. Both parties moved for summary judgment. Galloway acknowledged that it might be difficult for blind people to serve as jurors in some cases (e.g., those involving substantial documentary evidence) but opined that judges and parties involved in those cases should make those determinations on a case-by-case basis. Galloway presented evidence that: (1) a blind person had previously served as a judge in the Superior Court; (2) the Superior Court had no policy excluding deaf people from its jury pools and provided sign-language interpreters as reasonable accommodations; (3) in many cases, blind people could be reasonably accommodated by providing audio describers (people trained to describe physical movements, dress, and physical settings); (4) and blind jurors, like sighted jurors, could assess witnesses’ credibility by evaluating the content of testimony and witnesses’ tones and speech patterns. The Superior Court asserted that blind people were not qualified to perform the essential functions of jurors. The district court considered the parties’ summary-judgment motions.
Rule of Law
Holding and Reasoning (Green, J.)
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