## Facts

- Los Angeles County operated Rancho Los Amigos National Rehabilitation Center, a 207-bed facility providing specialized inpatient and outpatient rehabilitation and acute care for chronic conditions.
- Rancho served many insured patients; a substantial share were Medi-Cal recipients (about 67% of inpatients and 58% of outpatients).
- Facing a projected budget deficit, the County adopted a cost-reduction plan that included closing Rancho and dispersing or eliminating its specialized services.
- Plaintiffs were Medi-Cal recipients with disabilities who relied on Rancho’s coordinated, multidisciplinary rehabilitative programs (including services for spinal cord and brain injuries).
- Plaintiffs alleged the closure would eliminate access to needed integrated services and would increase the risk of deterioration, loss of independence, and placement in more restrictive institutional settings.
- Plaintiffs sued under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act, asserting disability discrimination and violation of the integration mandate.
- The district court granted a preliminary injunction barring the County from proceeding with closure unless necessary medical and rehabilitative services were provided elsewhere.

## Issues

1. Whether the district court abused its discretion in finding plaintiffs likely to succeed on their ADA Title II and Rehabilitation Act claims, including the integration mandate.
2. Whether the district court properly found irreparable harm, that the balance of hardships favored plaintiffs, and that an injunction served the public interest.

## Decision

- The Ninth Circuit affirmed the preliminary injunction.
- The court held the district court did not abuse its discretion in concluding plaintiffs showed a strong likelihood of success on the merits.
- The court agreed plaintiffs demonstrated irreparable harm if Rancho closed without equivalent services in place.
- The court held the balance of hardships tipped sharply toward plaintiffs and the public interest favored compliance with federal disability-discrimination law.
- The injunction remained in effect, preventing closure under the County’s plan absent provision of necessary services elsewhere.

## Legal Principles

- A preliminary injunction is reviewed for abuse of discretion; legal conclusions are reviewed de novo and factual findings for clear error.
- Under Ninth Circuit preliminary-injunction doctrine, relief may be granted on a showing of probable success and possible irreparable harm, or serious questions plus a sharply tipping balance of hardships.
- ADA Title II and § 504 prohibit disability-based exclusion or denial of benefits by public entities; the standards are substantially similar for these claims.
- Public entities must administer services in the most integrated setting appropriate and must make reasonable modifications to avoid discrimination unless doing so would fundamentally alter the program.
- Under the fundamental-alteration/undue-burden framework, the public entity bears the burden to show that requested modifications are unreasonable in light of available resources and program structure.
- Cost-saving justifications require concrete support; fiscal concerns alone do not defeat likely ADA/RA violations where the record does not establish fundamental alteration or undue burden.

## Conclusion

The Ninth Circuit upheld an injunction preventing Los Angeles County from closing a specialized public rehabilitation facility without ensuring necessary replacement services, finding a likely violation of the ADA and Rehabilitation Act’s integration requirements and concluding that threatened medical deterioration and institutionalization constituted irreparable harm outweighing the County’s asserted fiscal interests.


Rodde v. Bonta, 357 F.3d 988 (9th Cir. 2004)