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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

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)
Effective Date
2018-03-01

Other Sections in This Document (36)

Full Text

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Finally, “[t]he ‘equal opportunity’ element limits the ac-
commodation duty so that not every rule that creates a gen-
eral inconvenience or expense to the disabled needs to be
modified.” Id.
       Instead, the statute requires only accommoda-
       tions necessary to ameliorate the effect of the
       plaintiff’s disability so that she may compete
       equally with the non-disabled in the housing
       market. We have enforced this limitation by
       asking whether the rule in question, if left un-
       modified, hurts “handicapped people by reason
       of their handicap, rather than … by virtue of what
       they have in common with other people, such as
       a limited amount of money to spend on hous-
       ing.”
Id. (alterations in original) (quoting Hemisphere Bldg. Co., Inc.
v. Vill. of Richton Park, 171 F.3d 437, 440 (7th Cir. 1999)). In the
context of a zoning waiver, “‘equal opportunity’ means the
opportunity to choose to live in a residential neighborhood.”
Oconomowoc, 300 F.3d at 784.
    “The burden is on the plaintiffs to show that the accom-
modation it seeks is reasonable on its face.” Id. at 783. “Once
the plaintiffs have made this prima facie showing, the defend-
ant must come forward to demonstrate unreasonableness or
undue hardship in the particular circumstances.” Id.
       This burden-shifting analysis applies to the
       “necessary” and “equal opportunity” elements
       of the requirement as well, as “a plaintiff is in
       the best position to show what is necessary to
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