Martinez v. County of Alameda

Background

The court had previously denied the plaintiff’s motion for partial summary judgment and declaratory judgment, and had granted in part and denied in part the defendants’ motion for summary judgment. After a case-management conference, both sides asked the court to decide whether the County was required to provide scribe services under Title II of the Americans with Disabilities Act (ADA). The parties filed cross-motions for summary judgment on that issue. Summary judgment is a decision without a trial when the relevant facts are not genuinely disputed.

Court’s reasoning

The court concluded that it could not issue an order deciding whether scribe services were required in the abstract. Title II prohibits a public entity from excluding a qualified person with a disability from its services, programs, or activities, or denying that person their benefits because of the disability. The court found that this general rule did not allow it to decide whether one specific accommodation—scribe services—was required as a matter of law. The type of auxiliary aid required involves a fact-intensive inquiry that is often unsuitable for summary judgment. The court also noted that, even when scribes are provided, factual disputes may remain about whether the plaintiff’s claim for declaratory relief is moot.

Rulings and next steps

The court denied the parties’ cross-motions for summary judgment. It found that the plaintiff had shown good cause to amend her complaint and granted her motion for leave to amend. The plaintiff was ordered to file the amended complaint as a separate docket entry. Judge Thomas S. Hixson converted the July 13, 2023 hearing into a case-management conference and ordered the parties to file a conference statement by July 11, 2023. The parties were directed to discuss whether discovery should be reopened concerning the declaratory-relief claim and whether the remaining pretrial and trial dates should be rescheduled.