Valanzuolo v. City of New Haven, 972 F. Supp. 2d 263

Valanzuolo, a profoundly hearing-impaired resident of New Haven, was arrested on an outstanding failure-to-appear Housing Court warrant issued Oct. 20, 2009.
Plaintiff’s ADA/Fair Employment Practices Act claims arise from the arrest, hospitalization, and transport on Jan. 8, 2010.
City officials had prior dealings with plaintiff in 2009–2010 where communication was via pen-and-paper and interpreters were arranged in some instances.
The arrest proceeded under a FTA warrant with no discretion by officers; the dispute centers on whether reasonable accommodations were provided during arrest, hospitalization, and transport.
The court held judgment for the City, finding that plaintiff received effective communication throughout the events.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ADA Title II was violated by the arrest and detention.	Valanzuolo alleges failure to provide necessary accommodations.	Arrest was proper under a FTA warrant; accommodations not required beyond effective communication.	No ADA violation; communication deemed effective.
Whether ADA applies to post-arrest detention and transport.	ADA duties extend to hospital stay and van transport.	ADA applies; accommodations provided via pen-and-paper and later interpreter.	ADA applies; accommodations were effectively provided.
Whether the accommodations provided were reasonable under Lane/Bircoll framework.	ASL interpreter was necessary and should have been provided.	Pen-and-paper plus live interpreter when feasible; not required to change process.	Accommodations deemed reasonable; no denial of benefits.

Gorman v. Bartch, 152 F.3d 907 (8th Cir. 1998) (ADA applies to post-arrest detention and auxiliary aids)
Bircoll v. Miami-Dade Cnty., 480 F.3d 1072 (11th Cir. 2007) (factors for determining reasonable communication aids; pen-and-paper viable in many cases)
Tucker v. Tennessee, 539 F.3d 526 (6th Cir. 2008) (pen-and-paper as reasonable accommodation when effective)