Lyons v. Legal Aid Soc'y - 68 F.3d 1512 (2d Cir. 1995)

Rule:

Under either the Americans with Disabilities Act or the Rehabilitation Act, a plaintiff can state a claim for discrimination based upon her employer's failure to accommodate her handicap by alleging facts showing that the employer is subject to the statute under which the claim is brought, that she is an individual with a disability within the meaning of the statute in question, that, with or without reasonable accommodation, she could perform the essential functions of the job, and that the employer had notice of the plaintiff's disability and failed to provide such accommodation.

Facts:

Plaintiff Beth Lyons, a staff attorney employed by defendant Legal Aid Society ("Legal Aid"), appeals from a judgment of the district court dismissing her complaint alleging that Legal Aid violated her rights under, inter alia, the Americans with Disabilities Act of 1990, 42 U.S.C. §§ 12101-12213 (Supp. V 1993) ("ADA"), and the Rehabilitation Act of 1973, 29 U.S.C.  §§ 701-797b (1988 & Supp. V 1993) ("Rehabilitation Act") (collectively the "federal disability statutes"), principally by failing to provide her with a parking space near work. The district court, holding that the federal disability statutes imposed no such duty, dismissed Lyons's federal claims pursuant to Fed. R. Civ. P. 12(b)(6) for failure to state a claim on which relief can be granted. On appeal, Lyons contended that the complaint sufficiently stated claims on which relief can be granted under the federal statutes and that the reasonableness of the requested accommodation was a fact question that could not be decided without development of the record and pretrial discovery.

Issue:

Did the district court err in dismissing Lyon’s complaint for failure to state a claim on which relief can be granted?

Answer:

Yes

Conclusion:

Given the principle that a court should not grant a motion to dismiss for failure to state a claim unless it appeared beyond doubt that the plaintiff could prove no set of facts in support of his claim which would entitle him to relief, the court agreed that it was improper to dismiss the claim. Legal Aid’s assertion that it did not provide parking assistance to any other employee went beyond the face of the complaint and this assertion could not be the basis for a dismissal for failure to state a claim. The court found that in light of the need to develop a factual record, it was inappropriate to dismiss the complaint summarily. The court held that a reversal of the dismissal of federal claims required the reinstatement of state-law claims that were dismissed for lack of supplemental jurisdiction.