Price v. Howard County Public School System
1:22-cv-00541
D. MarylandMar 31, 2025Background
- Stephen Price, an African American former teacher with Howard County Public Schools (HCPS), suffers from depression, anxiety, and later a torn quadricep, resulting in mobility limitations.
- HCPS initially accommodated Price’s disabilities and medical restrictions (e.g., allowed him to sit while teaching, elevator access, and limited standing) and extended his leave as requested.
- Price requested additional accommodations for a student aide and assignment to a single, stationary classroom during the 2019–2020 school year, based on updated recommendations from a physician after his quad injury.
- HCPS attempted but was unable to provide a student aide due to scheduling and lack of volunteers, and explained that assigning Price to a single classroom would disrupt school operations and schedules.
- Price sued HCPS claiming failure to accommodate under the ADA, and later sought to add retaliation and disparate treatment claims after procedural deadlines had passed; only the ADA failure-to-accommodate claim remained for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to accommodate under ADA | Board failed by not providing a student aide or stationary classroom. | Accommodations requested were not necessary; Price could perform job; not reasonable/feasible. | No violation: Price could perform essential functions; accommodations not required. |
| Motion to amend complaint | Sought to add ADA retaliation and disparate treatment claims post-deadline. | Amendment untimely, undiligent, and would prejudice Board; facts were not newly discovered. | Denied: Not based on new facts; unjustified delay; prejudice. |
| Motion for surreply | Claimed Board raised new issues in summary judgment reply briefing. | Issues not new; Board raised them in opening summary judgment arguments. | Denied: No new issues warranting surreply. |
| Motion to strike affidavits | Claimed unfairness since he couldn’t depose affiants. | Had opportunity during discovery, failed to act; no basis for striking affidavits. | Denied: No prejudice or unjustified denial of opportunity. |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (sets the standard for summary judgment)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (clarifies what constitutes a genuine issue of material fact for summary judgment)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (court must view facts in light most favorable to nonmovant on summary judgment)
- School Bd. of Nassau County v. Arline, 480 U.S. 273 (1987) (describes essential function inquiry under disability discrimination framework)
- US Airways, Inc. v. Barnett, 535 U.S. 391 (2002) (explains reasonableness of accommodation required under the ADA)
- Wilson v. Dollar Gen. Corp., 717 F.3d 337 (4th Cir. 2013) (lays out prima facie elements for ADA failure-to-accommodate claims)
- Halpern v. Wake Forest Univ. Health Scis., 669 F.3d 454 (4th Cir. 2012) (describes plaintiff’s burden to show accommodation is reasonable)
- Laber v. Harvey, 438 F.3d 404 (4th Cir. 2006) (standards for granting leave to amend pleadings under Rule 15)