Barry Segal v. Metropolitan Council, 29 F.4th 399

Plaintiff Barry Segal is DeafBlind and relies on Metro Transit fixed-route buses, using T-signs to board and sometimes boarding to confirm route visually/verbally.
Between Sept. 2016 and Dec. 2019 Segal filed 150 complaints about drivers not stopping at T-signs or failing to pull forward; Metro Transit conceded those complaints were violations and verified 74 incidents.
During the relevant period Segal rode Metro Transit ~1,791 times; he estimates being late 5–10 times and missing about 3 appointments due to these incidents.
Metro Transit had prior training/policies for stopping at T-signs and took remedial steps after complaints (bulletins, coaching, signage), and reported far fewer ADA complaints relative to total rides.
District court granted summary judgment for Metro Transit finding it provided "meaningful access;" the Eighth Circuit reversed and remanded, finding genuine factual disputes for a jury to decide and that DOT regulations may be admitted as evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether violation of DOT regulations (49 C.F.R. §§ 37.167(c), 37.173) is a per se ADA violation or creates a private right of action	Segal: violation of DOT regs demonstrates ADA noncompliance and supports liability	Metro Transit: regulatory violation is not automatically an ADA violation; no separate private cause of action asserted	Court: refused per se rule and did not decide private cause of action; regulations are admissible evidence for jury to weigh
Whether Metro Transit denied Segal "meaningful access" under ADA/Rehab Act/MHRA	Segal: repeated failures to stop/announce denied substantially equal access compared to non-disabled riders	Metro Transit: provided training, remedial measures, and overall complaint rate was extremely low; thus provided meaningful access	Court: genuine issue of material fact exists; summary judgment improper; case remanded for trial
Whether the meaningful-access question is for a jury	Segal: factual disputes require jury factfinding	Metro Transit: argued court could decide as a matter of law	Court: meaningful-access is fact-intensive and belongs to the jury under the Seventh Amendment

Argenyi v. Creighton Univ., 703 F.3d 441 (8th Cir.) (summary judgment standard and plaintiff evidence burden)
Loye v. County of Dakota, 625 F.3d 494 (8th Cir.) (declining literal reading of ADA regulations as per se liability)
Alexander v. Choate, 469 U.S. 287 (U.S. 1985) (reasonable accommodation standard: equal opportunity, not identical results)
Childress v. Fox Assoc., LLC, 932 F.3d 1165 (8th Cir.) (comparing access provided to disabled and non-disabled peers)
Durand v. Fairview Health Servs., 902 F.3d 836 (8th Cir.) (identifying peer group context in meaningful-access analysis)