## Facts

- The Metropolitan Transportation Authority (MTA) and the New York City Transit Authority (NYCTA) designated about 123 of the New York City subway’s 472 stations as accessible to riders with mobility disabilities.
- Many accessible stations had only one elevator, and riders who relied on elevators alleged that outages occurred regularly, including at high-traffic stations and during peak commuting hours.
- Station elevators had electronic monitoring that detected malfunctions remotely and reported them to NYCTA.
- When a malfunction was detected, NYCTA’s control desk dispatched maintenance to investigate; if an outage was confirmed, control opened a work order and generated an estimated repair time.
- Confirmed outages were posted on MTA’s website, along with suggested alternate accessible routes.
- Riders could also sign up for email or text alerts tied to particular elevators.
- At stations, electronic signage notified riders of elevator outages, and signs at elevators directed riders toward alternate accessible routes.
- When an elevator was out of service, riders generally had several travel options: using another elevator at the same station (if available), transferring at a different accessible station, “back-riding” (traveling past a destination and returning via another line), or taking buses that ran along similar corridors.
- A group of individuals with mobility disabilities and disability-rights organizations sued MTA and NYCTA in a putative class action under Title II of the Americans with Disabilities Act and the Rehabilitation Act.
- Plaintiffs alleged that the elevator-outage conditions and the associated delays and hardships denied them meaningful access to the subway and that defendants failed to provide reasonable accommodations during outages.
- Plaintiffs sought additional measures, including outage announcements on trains, shuttle service to nearby accessible stations during outages, installation of backup elevators, and added training for subway employees to assist riders affected by outages.
- MTA and NYCTA moved for summary judgment, arguing that their outage communications and alternative travel options already amounted to reasonable accommodations.

## Issues

1. Whether, as a matter of law, MTA and NYCTA provided reasonable accommodations under Title II of the ADA and the Rehabilitation Act for riders with mobility disabilities during unplanned elevator outages at “accessible” subway stations.

## Decision

- The court granted summary judgment for MTA and NYCTA.
- The court held that the combination of outage detection and reporting, public outage information (website postings and alerts), station-level notices, and available alternate travel options constituted reasonable accommodations for elevator outages.
- The court concluded that the ADA and Rehabilitation Act did not require MTA and NYCTA to adopt plaintiffs’ preferred additional measures (such as onboard announcements, shuttle programs during outages, backup elevators, or expanded staffing/training) on the record presented.

## Legal Principles

- Title II of the ADA and § 504 of the Rehabilitation Act require public entities to provide qualified individuals with disabilities meaningful access to public services and programs.
- In an accommodations claim, the question is whether the entity’s measures are reasonable in light of the service provided; the statutes do not guarantee the most convenient or preferred accommodation.
- A public entity may satisfy its obligations through a set of measures that, taken together, give riders workable information and options when an accessibility feature is temporarily unavailable.
- Reasonableness is assessed with attention to practical alternatives and communications; a plaintiff’s proposed additional measures are not automatically required merely because they would reduce delay or inconvenience.

## Conclusion

Center for Independence of the Disabled, New York v. Metropolitan Transit Authority addressed whether subway riders who rely on elevators were denied meaningful access when elevators at accessible stations experienced outages. The court held that MTA and NYCTA’s outage monitoring and repair process, public and station-level outage notifications, and available alternate travel options amounted to reasonable accommodations under the ADA and Rehabilitation Act, and it granted summary judgment to the transit defendants.


Center for Independence of the Disabled, New York v. Metropolitan Transit Authority, 2024 WL 4008110 (2024)