RHJ Medical Center v. City of DuBois

RHJ Medical Center, Inc. (RHJ) (plaintiff) operated methadone treatment facilities in Pennsylvania. In 2006, RHJ decided to open a methadone treatment facility (the facility) in the city of DuBois. RHJ signed a lease for a site on Beaver Drive in DuBois. The site was zoned in the transitional district and was located adjacent to a sidewalk, Beaver Meadow Walkway, which was dedicated as a public park. Under Section 621 of the city’s zoning ordinance, methadone treatment centers were forbidden to operate within 500 feet of a public park without a certificate of use (certificate) from the municipal government. RHJ had renovated the space, hired staff, obtained the appropriate licenses, and opened the facility without obtaining a certificate. The city filed suit in trial court to enjoin RHJ from operating the facility until an application for a certificate was filed and approved. A permanent injunction was granted, and RHJ subsequently applied for a certificate. The city voted unanimously to deny RHJ’s application, asserting that RHJ did not present sufficient evidence to justify deviating from Section 621. RHJ appealed the city’s decision. The court of appeals found that Section 621 violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA). The city appealed and argued that RHJ lacked proper standing and moved for judgment on the pleadings.