## Facts

- Yasmin Reyazuddin, a completely blind Montgomery County employee, worked as a customer service representative using screen-reader software.
- The County consolidated multiple call centers into a centralized center, MC311, using Siebel customer-relationship software.
- The County concluded its Siebel implementation was incompatible with screen readers and placed an indefinite delay on transferring Reyazuddin to MC311.
- Sighted colleagues transferred to MC311; Reyazuddin was instead given assorted alternative tasks and positions that were sometimes not full-time and were characterized by some officials as not meaningful.
- Reyazuddin sought placement at MC311 in a comparable customer service role and proposed making MC311 accessible through a technology solution used elsewhere.
- The parties disputed the feasibility and cost of accessibility modifications: Reyazuddin’s estimate was about $129,600; the County asserted at least about $648,000 plus potential operational impacts.
- The County cited a small set-aside budget for disability accommodations relative to its overall budget, which exceeded $3.7 billion.
- Reyazuddin sued under § 504 of the Rehabilitation Act for failure to accommodate and under ADA Title II based on the County’s failure to hire her for an MC311 opening in 2012.

## Issues

1. Whether summary judgment was improper on the § 504 reasonable-accommodation claim because factual disputes existed over the cost, feasibility, and undue financial/administrative burden of making MC311 accessible.
2. Whether the County’s failure to hire Reyazuddin for an MC311 position in 2012 was actionable discrimination under ADA Title II.

## Decision

- The Fourth Circuit reversed summary judgment on the Rehabilitation Act claim and remanded for trial.
- The court held that genuine disputes of material fact existed on the reasonableness of the proposed accommodation and whether it would impose an undue financial or administrative burden.
- The court affirmed summary judgment for the County on the ADA Title II claim arising from the 2012 hiring decision.
- Disposition: affirmed in part, reversed in part, and remanded.

## Legal Principles

- Under § 504, a public employer must provide reasonable accommodation to a qualified individual with a disability unless doing so would impose an undue financial or administrative burden or fundamentally alter the program.
- Undue-burden analysis considers the accommodation’s cost in relation to the public entity’s overall resources, not merely a narrow accommodation line-item.
- At summary judgment, courts must not weigh competing expert evidence on cost or technical feasibility; material disputes on those questions require resolution by a factfinder.
- ADA Title II, addressing denial of benefits of a public entity’s services, programs, or activities, does not automatically provide a vehicle for challenging an employment hiring decision in the manner alleged.

## Conclusion

The Fourth Circuit held that disputed evidence about the cost, feasibility, and budgetary significance of making a centralized call center accessible precluded summary judgment on the Rehabilitation Act accommodation claim, while the plaintiff’s ADA Title II theory based on a later hiring decision failed as a matter of law.


Reyazuddin v. Montgomery County, 789 F.3d 407 (4th Cir. 2015)