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Lyons v. Legal Aid Society

United States Court of Appeals for the Second Circuit
68 F.3d 1512 (2d Cir. 1995)


Facts

Beth Lyons (plaintiff) was a staff attorney at the Legal Aid Society (Legal Aid) (defendant). In January 1989, Lyons began a disability leave of four-and-a-half years following a near-fatal car accident. After returning to work, Lyons was unable to walk long distances or stand for long periods of time. Lyons asked Legal Aid to accommodate her disability by paying for a parking space adjacent to her office and the courts where she practiced. Lyons’s doctor confirmed that a parking space was necessary for Lyons to return to work. Legal Aid refused to pay for the parking space. Lyons sued Legal Aid in the United States District Court for the Southern District of New York for refusing to accommodate Lyons’s disability under the Americans with Disabilities Act (ADA), 42 U.S.C. § 12101 et seq., and the Rehabilitation Act, 29 U.S.C. § 701 et seq. The district court held that Legal Aid did not have a duty to provide a parking space to Lyons and dismissed Lyons’s complaint for failure to state a claim. Lyons appealed.

Rule of Law

Issue

Holding and Reasoning (Kearse, J.)

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