Tyler v. City of Manhattan (1994)
- Sam Shepherd
- Sep 15
- 2 min read
By Leilani Acosta
Overview
Shortly after the passage of ADA, cities engaged in a self evaluation and transition process to ensure compliance. Specifically, in finding buildings that needed proper accommodations for the disabled community. Lewis Tyler, a wheelchair user, sues and argues that Manhattan violated ADA by incorrectly performing the self evaluation process, licensing inaccessible taverns and restaurants, and discriminating against him by failing to provide accommodations to city activities [1]. This case brings up the questions of the city’s role in ensuring compliance with ADA and the involvement of people with disabilities in these processes.
Summary
After the passage of ADA in 1990, cities like Manhattan and other political entities created ADA committees to ensure compliance with new regulations. The ADA and Attorney General would require a self evaluation and transition process. The self evaluation process required that the city evaluate regulations and services that need modifications, offer chances for involvement through comment submissions, and must keep it in public record for three years [1]. The transition plan was a follow up to self evaluation, outlining what steps would be taken, and schedule ramps and accommodations [1]. Tyler, a wheelchair user, was unable to attend a city hall meeting and argued that he was unable to access other public buildings. The court ruled in Tyler’s favor, deciding that the city was not following all ADA regulations and was using the Rehabilitation Act of 1973 as reference. The court also found that the city failed to properly execute the transition plan because they did not add accommodations during construction to existing facilities, failed to specify and list the current barriers, and did not appoint a designated person to oversee the transition plan [1].
Impact
This case reinforces ADA’s role in city planning, especially during construction on existing facilities. While this case takes place when ADA was first implemented, it creates a framework for political entities and ADA in properly implementing new regulations for the disabled community. For instance, the court noticed that the city was using the Rehabilitation Act, an existing law, as their reference for the new ADA regulations which resulted in lack of transparency during the transition process. If unchecked, this would have left people like Tyler without proper accommodations and barriers to events such as the city meeting. This case can be used as a framework to decide what processes or steps within both the evaluation and transition process succeeded or failed and how it can be more inclusive of disabled residents.
Court Documents
Lewis “Toby” Tyler v. City of Manhattan, Kansas, 849 F. Supp. (1429) (D. Kan. 1994)
Citations
Justia Law. (1994, April 18)
