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lawsuitplaintiffdefendantdiscriminationrehabilitation
defendantwillrehabilitation

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Badgett ex rel. Badgett v. Alabama High School Athletic Ass’n, Not Reported in F.Supp.2d, 2007 WL 2461928

Facts

Mallerie Badgett, a student with cerebral palsy at Oxford High School in Alabama, filed a lawsuit against the Alabama High School Athletic Association (AHSAA) seeking to participate in track and field events alongside able-bodied athletes. The AHSAA had established a separate wheelchair division for athletes with disabilities, which Badgett opposed, arguing it made her an exhibition rather than part of her team. The AHSAA's program allowed her to compete in a wheelchair division and earn medals, but Badgett wanted her points to count towards her school's able-bodied team total. The case centers on whether the ADA and the Rehabilitation Act require the AHSAA to accommodate her requests.

Issue

Whether the ADA and the Rehabilitation Act require the AHSAA to allow Mallerie Badgett to compete alongside able-bodied athletes and have her points count towards her team's total.

Whether the ADA and the Rehabilitation Act require the AHSAA to allow Mallerie Badgett to compete alongside able-bodied athletes and have her points count towards her team's total.

Rule

The ADA and the Rehabilitation Act prohibit discrimination against individuals with disabilities. To establish a claim under the ADA, a plaintiff must show they are a qualified individual with a disability who was excluded from participation or denied benefits due to their disability. The Rehabilitation Act has similar requirements but also necessitates that the defendant is a recipient of federal funds. Reasonable modifications must be made unless they fundamentally alter the nature of the program.

Analysis

The court found that Badgett's requests for modifications to compete alongside able-bodied athletes and have her points count towards the able-bodied division would fundamentally alter the nature of the track and field program. The AHSAA had already made reasonable modifications by creating a separate wheelchair division, which allowed Badgett to compete and earn recognition. The court noted that safety and fairness concerns justified the AHSAA's decision to maintain separate divisions.

The court finds that to the extent Defendants were obligated to modify the track and field program, they have met that obligation by establishing a separate wheelchair division for track and field. Athletes who compete in the wheelchair division will earn individual points, establish state records, and earn state championship medals for wheelchair track and field competition.

Conclusion

The court concluded that the AHSAA's establishment of a separate wheelchair division was a reasonable modification and that Badgett's claims under the ADA and the Rehabilitation Act were denied.

In light of the foregoing, the court finds no violation of the Rehabilitation Act of 1973 or Title II of the Americans with Disabilities Act.

Who won?

The prevailing party in this case is the Alabama High School Athletic Association (AHSAA). The court ruled in favor of the AHSAA, stating that they had made reasonable accommodations for Mallerie Badgett by creating a separate wheelchair division for track and field. The court emphasized that the modifications requested by Badgett would fundamentally alter the nature of the able-bodied track and field program, which justified the AHSAA's decision to maintain separate divisions for safety and fairness.

The court ruled in favor of the AHSAA, stating that they had made reasonable accommodations for Mallerie Badgett by creating a separate wheelchair division for track and field.

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