## Facts

- A project to revitalize downtown Camden included construction of a Camden Transportation Center integrating local facilities with PATCO high-speed rail service operated by the Delaware River Port Authority (DRPA) through its subsidiary.
- DRPA, a bi-state authority created by interstate compact between New Jersey and Pennsylvania and approved by Congress, conveyed certain property interests related to its former Broadway Station to the City of Camden.
- State barrier-free design requirements, enforced by the New Jersey Department of Community Affairs, called for accessible features, including elevator access for persons with mobility impairments.
- The dispute centered on providing accessible passage from street/main level to the PATCO platform within the Transportation Center, including whether DRPA could be compelled to allow installation of an elevator affecting PATCO access.
- Construction was financed in significant part through a federal urban mass transit grant, raising the effect of federal accessibility conditions tied to funding.

## Issues

1. Whether New Jersey may unilaterally apply its barrier-free design requirements to DRPA/PATCO facilities and operations within the Transportation Center, given DRPA’s interstate compact status.
2. Whether ownership or conveyance of the space proposed for an elevator allows application of New Jersey accessibility mandates despite DRPA’s compact protections.
3. Whether federal law and federal transit-funding conditions independently require accessible access between the Center’s main level and the PATCO platform.

## Decision

- The New Jersey Supreme Court reversed the rulings to the extent they subjected DRPA’s internal facilities and operations to unilateral New Jersey barrier-free design mandates.
- The court held that mandatory design changes directly affecting DRPA’s rail platform access and operations constituted regulation of DRPA’s internal operations, which New Jersey could not impose without express compact authority or concurrent legislation by both states.
- The court rejected a purely title-based approach; even if Camden held legal title to the elevator area, the functional impact on DRPA operations controlled the compact analysis.
- The court concluded that federal law and federal funding conditions applicable to the federally funded project required provision of accessible access between the main level and the PATCO platform.

## Legal Principles

- An interstate compact agency approved by Congress is not subject to unilateral regulation by one member state regarding internal operations and facilities absent express compact authorization or parallel legislation by both states.
- Courts evaluate compact preemption of state regulation functionally; state mandates that materially affect the agency’s core operations are treated as internal regulation even where a local entity holds title to affected space.
- Federal accessibility statutes, regulations, and funding conditions can impose independent, binding obligations on transit facilities and projects receiving substantial federal funds, notwithstanding limits on unilateral state regulation of a bi-state agency.

## Conclusion

The court held New Jersey could not unilaterally compel DRPA to comply with state barrier-free requirements where the required modifications would regulate DRPA’s internal operations, but it also enforced federal accessibility obligations arising from federal transit funding that required accessible access between the Transportation Center’s main level and the PATCO platform.


E. Paralyzed Veterans Ass’n, Inc. v. City of Camden, 545 A.2d 127 (N.J. 1988)