Mary Valencia v. City of Springfield, 883 F.3d 959 (2018)

Citation: Mary Valencia v. City of Springfield, 883 F.3d 959 (2018)
Parent Document: Mary Valencia v. City of Springfield, 883 F.3d 959 (2018)
Jurisdiction: United States (federal)
Effective Date: 2018-03-01
Original Source: https://www.courtlistener.com/opinion/4473714/mary-valencia-v-city-of-springfield/ ↗

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implement it.” Id. On the other hand, “[a]n accommodation is
unreasonable if it imposes undue financial or administrative
burdens or requires a fundamental alteration in the nature of
the program.” Id.
    Some costs related to reasonableness “may be objective
and easily ascertainable.” Wis. Cmty. Servs., 465 F.3d at 752.
For example, “some governmental costs associated with the
specific program at issue may be a matter of simply looking
at a balance sheet.” Id. Other costs “may be more subjective
and require that the court demonstrate a good deal of wisdom
in appreciating the intangible but very real human costs asso-
ciated with the disability in question.” Id. This refers to “those
intangible values of community life that are very important if
that community is to thrive and is to address the needs of its
citizenry.” Id. Of particular relevance here, “[a] zoning waiver
is unreasonable if it is so ‘at odds with the purposes behind
the rule that it would be a fundamental and unreasonable
change.’” Oconomowoc, 300 F.3d at 784 (quoting Dadian v. Vill.
of Wilmette, 269 F.3d 831, 838–39 (7th Cir. 2001)).
    “Whether the requested accommodation is necessary re-
quires a ‘showing that the desired accommodation will af-
firmatively enhance a disabled plaintiff’s quality of life by
ameliorating the effects of the disability.’” Dadian, 269 F.3d at
838 (quoting Bronk v. Ineichen, 54 F.3d 425, 429 (7th Cir. 1995)).
“In other words, the plaintiffs must show that without the re-
quired accommodation they will be denied the equal oppor-
tunity to live in a residential neighborhood.” Oconomowoc, 300
F.3d at 784. “This has been described by courts essentially as
a causation inquiry.” Wis. Cmty. Servs., 465 F.3d at 749.
No. 17-2773                                                      15

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