## Facts

- Elaine Aikins, a deaf woman, brought suit with the California Association of the Deaf (CAD) against St. Helena Hospital and Dr. James Lies, an emergency-room physician affiliated with the hospital as an independent contractor.
- On October 30, 1992, Elaine’s husband suffered a cardiac arrest at home and was transported by paramedics to St. Helena Hospital.
- Dr. Lies decided to perform emergency angioplasty and attempted to consult Elaine and obtain consent, but she could not understand him and requested interpreters.
- A hospital operator with limited fingerspelling attempted to communicate briefly but stopped after becoming frustrated.
- Neighbors attempted to assist communication; the parties disputed whether these efforts conveyed the critical information needed for meaningful decision-making.
- The hospital did not provide a qualified sign-language interpreter or other effective auxiliary aid during the early period when key medical decisions were made.
- Several days later, with family assistance, Elaine communicated with Dr. Lies and later requested removal of life support; her husband died thereafter.
- Plaintiffs alleged violations of ADA Title III, § 504 of the Rehabilitation Act, and California civil-rights laws based on ineffective communication and the absence of auxiliary aids; defendants asserted, among other defenses, undue burden.

## Issues

1. Whether an independent-contractor emergency-room physician may be subject to ADA Title III obligations in connection with services provided at a hospital.
2. Whether allegations that defendants failed to provide qualified interpreters or other effective auxiliary aids plausibly state discrimination under ADA Title III and § 504 of the Rehabilitation Act.
3. Whether defendants were entitled to dismissal or summary judgment based on an “undue burden” defense given the emergency context and disputed facts about feasibility and resources.
4. Whether CAD had organizational or associational standing to seek relief concerning accessibility practices affecting its members.
5. What forms of relief were available under the asserted statutes at the motion-to-dismiss/summary-judgment stage.

## Decision

- The court granted in part and denied in part defendants’ motions to dismiss and, alternatively, for summary judgment.
- The court permitted core ADA Title III and Rehabilitation Act claims regarding failure to provide effective communication to proceed against the hospital.
- The court rejected a categorical argument that Dr. Lies’s independent-contractor status, by itself, barred ADA Title III liability, allowing significant aspects of the claims against him to proceed.
- The court declined to resolve the undue-burden defense on summary judgment due to fact-intensive disputes about effective communication, feasibility, and the hospital’s resources.
- The court declined to dismiss CAD at the motion stage, finding sufficient allegations to support standing at least for prospective declaratory and injunctive relief.
- The court narrowed certain claims and/or remedies (including limits associated with Title III relief), granting dismissal or summary judgment in part.

## Legal Principles

- Hospitals are places of public accommodation under ADA Title III and must provide auxiliary aids and services when necessary to ensure effective communication with individuals who are deaf or hard of hearing.
- ADA Title III coverage may extend to health-care providers associated with a facility when the allegations concern their role in providing services at a place of public accommodation; independent-contractor status is not automatically dispositive.
- Under ADA Title III and § 504, ad hoc or untrained communication methods may be insufficient when they do not provide effective communication about material medical decisions.
- An undue-burden defense requires proof of significant difficulty or expense in light of the entity’s resources and circumstances; where feasibility and effectiveness are disputed, summary judgment is commonly inappropriate.
- An advocacy organization may have associational standing to pursue declaratory or injunctive relief when members would have standing, the interests align with the organization’s purpose, and the relief sought does not require individualized participation.

## Conclusion

The court largely allowed claims to proceed that the hospital and affiliated emergency-room physician failed to ensure effective communication with a deaf patient’s spouse during critical treatment decisions, held that undue burden and adequacy of auxiliary aids presented factual disputes, and permitted an advocacy organization to remain in the case for prospective relief while narrowing some theories and remedies.


Aikins v. St. Helena Hosp., 843 F. Supp. 1329 (N.D. Cal. 1994)