Henrietta D. v. Bloomberg

New York City (city) (defendant) oversaw local administration of the state’s public-assistance benefits programs. The city enacted the Division of AIDS Services and Income Support (DASIS) law, which formed DASIS, an agency within the city’s social-services department that was intended to provide better access to public benefits for individuals with acquired immunodeficiency syndrome (AIDS) (AIDS patients) (plaintiffs). AIDS patients had weakened immune systems, putting the patients at risk of severe infections that limited daily life activities like traveling, standing in line, and attending appointments. To facilitate access to welfare benefits, the DASIS law implemented procedural rules concerning caseworker-client ratios and time limits between welfare applications and the provision of benefits. Most programs that DASIS helped facilitate were available to nondisabled individuals in addition to AIDS patients, but a few services, such as emergency shelter allowances and rental assistance, were specific to AIDS patients. AIDS patients sued the city, claiming that DASIS failed in its duty to provide meaningful access to the patients’ benefits. The record established that DASIS systemically failed to provide AIDS patients with the services the agency was intended to facilitate. Wait times were egregious, case managers were overloaded, and communication was notoriously inconsistent. However, nondisabled individuals seeking public benefits and services experienced similar difficulties. The district court found that (1) the AIDS patients required special accommodations to access their guaranteed public benefits; (2) the DASIS law was intended to provide those accommodations; and (3) the city failed to comply with the DASIS law in practice, denying the AIDS patients meaningful access to their benefits in violation of the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The court issued an injunction requiring the city to implement the DASIS law as written. The city appealed to the Second Circuit, arguing that because disabled and nondisabled individuals experienced the same difficulties, the AIDS patients did not experience discrimination based on their disabilities.