Reyazuddin v. Montgomery County, Maryland

In 2008, Montgomery County, Maryland (the county) (defendant) opened a consolidated call center called MC311. Yasmin Reyazuddin (plaintiff), a blind woman, had worked for the county’s department of health and human services in a comparable job since 2002. The county planned to transfer Reyazuddin to MC311 but ultimately refused, claiming that it would be too expensive to make MC311’s software accessible to Reyazuddin. Instead, Reyazuddin’s supervisors pieced together assignments that amounted to only part-time work. Reyazuddin sued the county in federal district court, arguing that the county had violated Section 504 of the Rehabilitation Act by failing to reasonably accommodate her disability. Additionally, Reyazuddin alleged that the county had violated Title II of the Americans with Disabilities Act (ADA) by failing to hire her for a vacant MC311 position in 2012. The county moved for summary judgment. Reyazuddin’s expert witness stated that a specific technology solution that had worked in other call centers could make MC311’s software compatible with Reyazuddin’s screen-reader software and estimated that it would cost $129,600 to implement. The county’s expert countered that the solution’s lowest possible cost was $648,000. The county also argued that Reyazuddin’s proposed accommodations would alter MC311’s employee-facing portion, which could increase server downtime, in turn creating negative user experiences. The county also emphasized its tiny budget for disability accommodations: $500 for each department and an extra $15,000 in the county’s overall budget (which totaled $3.73 billion in 2010). The district court granted the county’s summary-judgment motion, crediting the county’s arguments and finding that the proposed accommodation’s high cost would present an undue burden. Reyazuddin appealed.