## Facts

- Disabled plaintiffs sued MARTA, a public entity operating Atlanta-area bus and rail service and complementary paratransit.
- Plaintiffs included riders who were blind or visually impaired and riders who used wheelchairs, alleging barriers across fixed-route and paratransit services.
- Plaintiffs sought declaratory and injunctive relief for an alleged system-wide pattern and practice of disability discrimination.
- Claims were brought under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act.
- Plaintiffs alleged ongoing accessibility failures affecting mobility and equal use of transit, including problems with accessibility equipment and paratransit operations.
- Visually impaired plaintiffs alleged MARTA did not provide schedule/route information in accessible formats, including failures to supply promised braille information and online information that was unusable with screen-reader software.
- Plaintiffs moved for a preliminary injunction; they withdrew a prior motion for class certification before the court ruled on injunctive relief.

## Issues

1. Whether plaintiffs showed a substantial likelihood of success on the merits of their ADA Title II and Rehabilitation Act claims challenging MARTA’s fixed-route, paratransit, and information/communication practices.
2. Whether plaintiffs showed irreparable harm absent preliminary relief.
3. Whether the balance of harms favored granting an injunction.
4. Whether an injunction would be consistent with the public interest and appropriately tailored to the evidentiary record.

## Decision

- The court granted in part and denied in part the motion for a preliminary injunction.
- The court found plaintiffs demonstrated a likelihood of success on at least some claims that MARTA’s practices denied meaningful access and failed to provide effective communication, including certain information-access barriers for visually impaired riders.
- The court credited evidence of ongoing, non-compensable harm to plaintiffs’ ability to use public transportation and to receive necessary information.
- The court found the balance of harms and public interest favored enforcing federal disability-rights requirements where violations were likely.
- The court limited or denied relief on claims where the preliminary record was insufficient or the requested remedy was overly broad at the preliminary stage.

## Legal Principles

- Title II of the ADA and § 504 of the Rehabilitation Act prohibit disability-based exclusion and discrimination by covered public entities and federally funded programs, including public transportation providers.
- Plaintiffs seeking a preliminary injunction must show: (1) likelihood of success on the merits, (2) irreparable injury absent relief, (3) that threatened injury outweighs harm to the defendant, and (4) that relief is not adverse to the public interest.
- Covered public entities must provide individuals with disabilities meaningful access to public services; compliance is assessed by practical ability to use the service, not by theoretical availability.
- Title II’s effective-communication requirements obligate public entities to provide information to individuals with disabilities as effectively as to others, using appropriate auxiliary aids and services when needed.
- Preliminary injunctive relief should be tailored to address demonstrated likely violations and supported barriers, rather than imposing untethered system-wide mandates on a limited record.

## Conclusion

The court partially enjoined MARTA after finding plaintiffs were likely to succeed on certain ADA and Rehabilitation Act theories, including failures to provide effective communication and accessible transit information, while withholding broader relief where the preliminary evidentiary showing was inadequate.


Martin v. Metro. Atl. Rapid Transit Auth., 225 F. Supp. 2d 1362 (N.D. Ga. 2002)