Case: United Handicapped Federation v. Andre

4:75-cv-00627 | U.S. District Court for the District of Minnesota

Filed Date: June 13, 1980

Closed Date: June 11, 1980

Clearinghouse coding complete

Case Summary

This case summary is based on four published opinions from the case. We have no other documents.This case was filed in the United States District Court for the District of Minnesota in 1975. The plaintiffs, the United Handicapped Federation, another disability advocacy group, and six individuals with mobility disabilities, filed the suit against the Chief Administrator of the Minneapolis/St. Paul Metropolitan Transit Commission (MTC), the Secretary of the United States Department of Transportat…

This case summary is based on four published opinions from the case. We have no other documents.

This case was filed in the United States District Court for the District of Minnesota in 1975. The plaintiffs, the United Handicapped Federation, another disability advocacy group, and six individuals with mobility disabilities, filed the suit against the Chief Administrator of the Minneapolis/St. Paul Metropolitan Transit Commission (MTC), the Secretary of the United States Department of Transportation, the Administrator of the Federal Urban Mass Transportation Administration (UMTA), and the AM General Corporation. The plaintiffs alleged that the pending purchase of 338 non-wheelchair-accessible buses violated Section 504 of the Rehabilitation Act of 1973, § 16(a) of the Urban Mass Transportation Act of 1964 as amended, §§ 105(a) and (b) of the Federal-Aid Highway Amendments of 1974, § 315 of the Department of Transportation and Related Agencies Appropriations Act of 1975, and the Fourteenth Amendment of the U.S. Constitution, by way of 42 U.S.C. § 1983, which allows private actions against states for violations of federally guaranteed rights under color of state law. Plaintiffs also raised state law claims. They sought preliminary and permanent injunctions preventing MTC from acquiring inaccessible buses.

The District Court (Judge Donald D. Alsop) denied the plaintiffs' motion for a preliminary injunction, and granted summary judgment for the defendants, finding that none of the statutes on which the plaintiffs based their claims required that all buses bought using federal funds be equipped to transport passengers in wheelchairs. The Court held that the state had made sufficient special efforts to aid the disabled in their use of the mass transportation system so as to fulfill its obligations under federal law. United Handicapped Federation v. Andre, 409 F.Supp. 1297 (D. Minn. 1976).

The plaintiffs appealed the decision. The Eighth Circuit Court of Appeals (Judge Donald Pomery Lay) reversed the lower court's decision and remanded the case. This decision was made in light of UMTA's having issued, after the lower court's decision, new regulations by its authority under § 504 of the Rehabilitation Act of 1973, 29 U.S.C.S. § 794, which conditioned the approval of mass transit system projects on special efforts for elderly and handicapped persons, specifically including wheelchair users and semiambulatory persons. The 8th Circuit Court held that § 504 created an affirmative duty on the part of the state, and that the plaintiffs had standing to bring a private cause of action. United Handicapped Federation v. Andre, 558 F.2d 413 (8th Cir. 1977). At some point around this time, it appears that the purchase of the inaccessible buses was completed.

After this, the District Court dismissed all claims against AM General Corporation and the claims against all defendants relating to transportation projects approved by UMTA prior to April 27, 1976. The parties then negotiated a settlement, wherein it appears that the remaining defendants agreed to convert MTC's entire fleet to be wheelchair accessible within a few years of the settlement's date of execution. The settlement left the issue of attorneys' fees undecided.

In 1980, the District Court denied the plaintiffs' motion for reasonable attorneys' fees and costs, finding that they were not the "prevailing party" and that therefore they were not entitled to an award of costs. United Handicapped Federation v. Andre, 489 F.Supp. 1040 (D. Minn. 1980). The Eighth Circuit (Judge Lay) reversed this decision, remanding the issue to the lower court with instructions to award reasonable attorneys' fees not to exceed $10,000 and legal costs of $2,500. United Handicapped Federation v. Andre, 622 F.2d 342 (8th Cir, 1980).

Summary Authors

Alex Colbert-Taylor (8/6/2013)

People


Judge(s)

Alsop, Donald Douglas (Minnesota)

Lay, Donald Pomery (Minnesota)

Judge(s)

Alsop, Donald Douglas (Minnesota)

Lay, Donald Pomery (Minnesota)

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Documents in the Clearinghouse

Document

4:75-cv-00627

Memorandum and Order

March 11, 1976

March 11, 1976

Order/Opinion

409 F.Supp. 409

76-01369

Opinion [Vacating Grant of Summary Judgment and Remanding Case]

U.S. Court of Appeals for the Eighth Circuit

June 21, 1977

June 21, 1977

Order/Opinion

558 F.2d 558

79-01606

Opinion

U.S. Court of Appeals for the Eighth Circuit

May 14, 1980

May 14, 1980

Order/Opinion

622 F.2d 622

4:75-cv-00627

Memorandum Order

June 11, 1980

June 11, 1980

Order/Opinion

489 F.Supp. 489

Docket

Last updated Feb. 19, 2024, 3:09 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Minnesota

Case Type(s):

Public Benefits/Government Services

Key Dates

Filing Date: June 13, 1980

Closing Date: June 11, 1980

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Two disability advocacy organizations and six mobility-disabled individuals, seeking to enjoin the purchase of inaccessible buses.

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Minneapolis/St. Paul Metropolitan Transit Commission (Minneapolis/St. Paul), City

U.S. Department of Transportation , Federal

Urban Mass Transportation Administration, Federal

Defendant Type(s):

Transportation

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.

Section 504 (Rehabilitation Act), 29 U.S.C. § 701

State law

Constitutional Clause(s):

Equal Protection

Available Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Attorneys fees

Source of Relief:

Settlement

Litigation

Form of Settlement:

Court Approved Settlement or Consent Decree

Voluntary Dismissal

Amount Defendant Pays: Less than $12,500

Order Duration: 1980 - None

Content of Injunction:

Preliminary relief denied

Discrimination Prohibition

Issues

General:

Access to public accommodations - governmental

Public benefits (includes, e.g., in-state tuition, govt. jobs)

Transportation

Disability and Disability Rights:

Reasonable Modifications

Mobility impairment

Discrimination-area:

Disparate Impact

Discrimination-basis:

Disability (inc. reasonable accommodations)

Type of Facility:

Government-run