Tyler v. City of Manhattan

After the Americans with Disabilities Act (ADA) was passed, the Department of Justice created regulations requiring public entities to conduct self-evaluations of their services, policies, and practices and to begin making modifications as needed to comply with ADA requirements. Under the Rehabilitation Act, many covered entities had already conducted self-evaluations. However, because several years had passed since these evaluations were conducted and because the ADA enlarged the scope of covered programs and services, many of those entities had to redo and expand their self-evaluations. If an entity chose to structurally modify any existing facilities, it also had to produce a transition plan that identified (1) specific physical obstacles requiring alterations, (2) the methods needed to improve the areas, (3) a schedule of steps that would be taken to implement improvements, and (4) an official responsible for plan implementation. The City of Manhattan (city) (plaintiff) conducted a self-evaluation to comply with the ADA regulations. The evaluation included exact duplicates of the city’s Rehabilitation Act evaluation documents but included two new pages, one of which was the city’s antidiscrimination policy. The city also created a transition plan that included a prioritized list of necessary changes to general areas of facilities and structures. The plan lacked information on improvement methods, timelines for improvements, and responsible officials. Lewis Tyler (plaintiff), a disabled resident, filed suit in federal district court, claiming that the self-evaluation and transition plan were not sufficient to satisfy the ADA. The city moved for summary judgment.