## Facts

- RHJ Medical Center, Inc. operated methadone treatment facilities in Pennsylvania and planned to open a clinic in the City of DuBois.
- RHJ leased and renovated space on Beaver Drive in a “transitional district,” adjacent to a city-designated public park (the Beaver Meadow Walkway).
- A municipal zoning provision barred methadone treatment facilities (and similar uses) within 500 feet of a public park unless the operator obtained a discretionary municipal “certificate of use.”
- RHJ opened the clinic without first obtaining the certificate.
- The City sued in state court and obtained a permanent injunction preventing operation unless and until the certificate was granted.
- RHJ applied for the certificate; the City Council unanimously denied it, stating there were insufficient grounds to deviate from the ordinance’s locational restriction.
- RHJ then sued the City in federal court, alleging violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA), among other theories, based on the ordinance and the certificate denial.
- The City moved for judgment on the pleadings and, alternatively, for a more definite statement.

## Issues

1. Whether RHJ had standing to assert ADA and RA claims based on the clinic’s inability to operate and serve individuals receiving methadone treatment.
2. Whether the complaint plausibly stated ADA/RA claims challenging the ordinance and the City’s denial of the certificate, such that judgment on the pleadings was improper.
3. Whether prior state-court proceedings (including the injunction) barred the federal claims at the pleadings stage.
4. Whether the complaint was so vague or ambiguous that the City was entitled to a more definite statement under Rule 12(e).

## Decision

- The court denied the City’s motion for judgment on the pleadings.
- The court denied the City’s motion for a more definite statement.
- The court held that the complaint adequately alleged that individuals seeking methadone treatment are persons with disabilities protected by the ADA and RA.
- The court held that RHJ adequately alleged injury and thus had standing, including economic harm and impediments to providing services to its disabled clientele.
- Accepting the pleaded facts as true, the court concluded RHJ plausibly alleged that the ordinance and its enforcement imposed special burdens on methadone clinics and could reflect discriminatory treatment rather than legitimate land-use concerns.
- The court declined to conclude, at the pleadings stage, that the state-court injunction or related doctrines precluded or otherwise barred the federal ADA/RA claims.
- The court found the complaint provided fair notice of the challenged ordinance provisions, their application to the Beaver Drive site, and the certificate denial, making Rule 12(e) relief unwarranted.

## Legal Principles

- Individuals receiving methadone treatment for opioid dependence may qualify as persons with disabilities protected by the ADA and RA.
- A treatment-facility operator may have standing to sue under the ADA/RA when zoning restrictions or permitting decisions prevent operation and burden services to disabled clients.
- At the Rule 12(c) stage, the court must accept well-pleaded factual allegations as true and draw reasonable inferences in the nonmovant’s favor; plausible ADA/RA discrimination allegations are sufficient to proceed.
- Zoning schemes that single out methadone clinics for special locational restrictions and discretionary approvals may support claims of unlawful discrimination under the ADA and RA.
- Rule 12(e) relief is improper where the complaint gives fair notice of the claims and the factual basis for them.

## Conclusion

The court allowed RHJ’s ADA and Rehabilitation Act claims to proceed, holding that the pleadings plausibly alleged discriminatory zoning and permitting treatment of a methadone clinic and that the complaint was sufficiently definite to require an answer.


RHJ Med. Ctr., Inc. v. City of DuBois, 754 F. Supp. 2d 723 (W.D. Pa. 2010)