Meagley v. City of Little Rock
639 F.3d 384
8th Cir.2011Background
- Meagley injured when her rental scooter tipped over on a slope near the Siamang Exhibit at the Little Rock Zoo.
- She sued the City of Little Rock under the ADA and Rehabilitation Act for discriminatory conditions creating the injury risk.
- District court found no intentional discrimination, concluded scooter fee was not an illegal surcharge, and held Meagley lacked standing to challenge a post-injury liability waiver.
- Bridges near the Siamang Exhibit were rebuilt to be essentially level after a DOI self-evaluation; the injuries occurred before the renovations.
- Zoo began requiring waiver of tort claims for scooter rentals after Meagley’s accident; the waiver did not cover ADA/Rehabilitation Act claims.
- Meagley appealed the district court’s rulings; the Eighth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Must a plaintiff prove intentional discrimination to obtain compensatory damages? | Meagley contends no heightened standard; intent not required. | City argues deliberate indifference or intentional discrimination is required. | Intentional discrimination required to recover compensatory damages. |
| What standard proves intentional discrimination in ADA/Rehabilitation Act claims for damages? | Meagley asserts deliberate indifference standard is too strict or unnecessary. | City maintains deliberate indifference is proper for this context. | Deliberate indifference standard applies; Meagley failed to show it. |
| Is the zoo's scooter rental fee an impermissible surcharge under 28 C.F.R. § 35.130(f)? | Fee constitutes an illegal surcharge for disabled individuals. | Fee is a general service charge; scooters were available to all and not mandated for the disabled. | Fee not an illegal surcharge. |
| Does Meagley have standing to challenge the zoo's post-accident liability waiver? | Meagley seeks prospective relief and injury in fact from the waiver. | No imminent future injury or intent to return shown; lacks standing. | Meagley lacks standing to challenge the waiver. |
Key Cases Cited
- Barber ex rel. Barber v. Colo. Department of Revenue, 562 F.3d 1222 (10th Cir. 2009) (deliberate indifference standard recognized for damages in similar actions)
- Nieves-Marquez v. Puerto Rico, 353 F.3d 108 (1st Cir. 2003) (damages under ADA/Rehabilitation Act require intentional discrimination)
- Delano-Pyle v. Victoria County, 302 F.3d 567 (5th Cir. 2002) (consistent stance on damages and intentional discrimination)
- Garcia v. S.U.N.Y. Health Sciences Ctr. of Brooklyn, 280 F.3d 98 (2d Cir. 2001) (requires intentional discrimination for compensatory damages)
- Duvall v. County of Kitsap, 260 F.3d 1124 (9th Cir. 2001) (supports intentional-discrimination requirement for damages)
- Pandazides v. Va. Bd. of Education, 13 F.3d 823 (4th Cir. 1994) (Rehabilitation Act/Title VI alignment on damages proof)
- Wood v. President & Trs. of Spring Hill College, 978 F.2d 1214 (11th Cir. 1992) (damages standards under federal statutes for disabilities cases)
- Guardians Ass'n v. Civil Serv. Comm'n, 463 U.S. 582 (1983) (no compensatory relief without discriminatory animus in Title VI contexts)
- Alexander v. Sandoval, 532 U.S. 275 (2001) (ties on discrimination remedies under related statutes)
- Barnes v. Gorman, 536 U.S. 181 (2002) (punitive damages generally not available; does not hold no intent proof for compensatory damages)