## Facts

- A certified class of indigent New York City residents with AIDS or symptomatic HIV relied on City-administered public assistance programs, including cash assistance, food stamps, and Medicaid.
- New York City enacted a local DASIS law creating a specialized unit to help eligible individuals with AIDS/HIV access and maintain benefits, including targeted case management, caseload ratios, and timelines for processing and delivery of benefits.
- The class alleged that DASIS failed to deliver the specialized assistance contemplated by the DASIS law, with high caseloads, severe delays, lost paperwork, and inconsistent communication.
- The City argued the same administrative failures affected non-disabled recipients, contending plaintiffs were not harmed “because of” disability.
- After a bench trial, the district court found violations of ADA Title II and § 504 for denying “meaningful access” and issued broad injunctive relief ordering the City to implement the DASIS law; it also imposed liability on a state social services official based on supervisory responsibility.
- City and state defendants appealed, challenging disability-statute liability, the scope of the injunction, and issues related to the state official and sovereign immunity.

## Issues

1. Whether an ADA Title II/§ 504 reasonable-accommodation claim requires proof that disabled persons were treated worse than non-disabled persons, or instead requires proof of denial of meaningful access by reason of disability.
2. Whether “discrimination” can be established when a public benefits system is dysfunctional for both disabled and non-disabled applicants.
3. Whether an injunction compelling compliance with the DASIS law is permissible relief as a reasonable accommodation under ADA Title II and § 504.
4. Whether prospective relief against a state official in an official capacity is barred by sovereign immunity, and the extent of the state official’s responsibility for city administration.

## Decision

- The Second Circuit affirmed the core holdings that the City violated ADA Title II and § 504 by failing to provide reasonable accommodations necessary for plaintiffs to have meaningful access to public benefits.
- The court held plaintiffs need not prove they were treated worse than non-disabled persons; denial of meaningful access by reason of disability is sufficient.
- The court rejected the argument that a generally “broken” welfare system defeats causation, reasoning that HIV/AIDS-related impairments can make ordinary administrative burdens (travel, repeated visits, long waits, crowded offices) uniquely hazardous and exclusionary without accommodations.
- The court upheld the central injunctive relief requiring the City to implement the DASIS law as an appropriate, tailored accommodation method.
- The court recognized that ADA Title II and § 504 impose largely parallel standards on state and local governments.
- The court limited aspects of the district court’s rulings concerning the state official and related non-core claims, while acknowledging that prospective relief against state officials to end ongoing federal-law violations may proceed under the Ex parte Young doctrine.

## Legal Principles

- Under ADA Title II and § 504, a plaintiff alleging failure to provide reasonable accommodation must show denial of meaningful access to a public benefit by reason of disability; proof of worse treatment than non-disabled persons is not required.
- Discrimination under these statutes includes failure to make reasonable modifications to ensure meaningful access to a facially neutral program.
- A public entity cannot avoid accommodation duties by asserting the underlying program is poorly administered for everyone; if disabled persons face disability-related barriers that make access ineffective absent modifications, reasonable accommodations may be required.
- Injunctive relief may properly require implementation of an existing governmental accommodation framework when it functions as a reasonable method to secure meaningful access.
- For state and local government services, ADA Title II and § 504 generally apply the same substantive standard, absent a statute-specific difference that matters on the facts.
- Sovereign immunity does not bar prospective injunctive relief against state officials in their official capacities to remedy ongoing violations of federal law.

## Conclusion

The Second Circuit held that New York City’s failure to provide the specialized assistance required for people with AIDS/HIV denied them meaningful access to public benefits in violation of ADA Title II and § 504, and it approved injunctive relief compelling implementation of the City’s own accommodation scheme, notwithstanding broader administrative dysfunction.


Henrietta D. v. Bloomberg, 331 F.3d 261 (2d Cir. 2003)