Seremeth v. Board of County Commissioners, 673 F.3d 333

Seremeth, a deaf individual, was involved in a domestic disturbance with Frederick County deputies on January 13, 2008.
Deputies handcuffed Seremeth behind his back, hindering his ability to communicate by notes or signing.
No qualified interpreter was provided on scene; a trainee ASL worker arrived late and Seremeth relied on his father to interpret.
The sheriff’s office had a contract for qualified interpreters with an emergency arrival within one hour, though this did not occur.
Seremeth filed suit on January 12, 2009, alleging violations of the ADA Title II and the Rehabilitation Act; the district court granted summary judgment for the Appellees.
The Fourth Circuit held that the ADA applies to police investigations and that the accommodations provided were reasonable under exigent circumstances, affirming the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the ADA cover police investigations?	Seremeth contends yes, as investigations fall within ADA scope.	Appellees contend no, or not required in this context.	Yes, ADA applies to the investigation.
Are the provided accommodations reasonable under the circumstances?	Seremeth argues accommodations were insufficient (no front-of-body handcuffing, no qualified interpreter).	Appellees argue accommodations were reasonable given danger and need for quick information.	Accommodations were reasonable under exigent circumstances.
Must departments provide best practices regardless of danger?	Seremeth seeks more extensive accommodations beyond the minimum.	Officers are not required to implement optimal procedures in emergency contexts if reasonable accommodations are made.	Not required to adopt best practices; operative accommodations were reasonable.

Rosen v. Montgomery County, 121 F.3d 154 (4th Cir. 1997) (injury requirement limits ADA coverage in arrests; later cases question broad applicability)
Yeskey v. Pennsylvania Dept. of Corrections, 524 U.S. 206 (U.S. 1998) (ADA coverage expanded to include certain state-court contexts; interpretive framework used)
Waller v. Danville, 556 F.3d 171 (4th Cir. 2009) (ADA liability in police interrogations under reasonable-accommodation framework)
Pandazides v. Va. Bd. of Educ., 13 F.3d 823 (4th Cir. 1994) (reasonableness of accommodations depends on circumstances)
Constantine v. Rectors and Visitors of George Mason Univ., 411 F.3d 474 (4th Cir. 2005) (illustrates disjunctive reach in § 12132 analysis)