Foley V. City Of Lafayette

Robert Foley alleges that the City of Lafayette violated the Americans with Disabilities Act ("ADA") and the Rehabilitation Act of 1973 by failing to provide adequate egress from the city-owned train-station platform. The district court, relying on 49 C.F.R. § 37.161, concluded that the inoperable elevators and snow-covered ramp that prevented Foley from an easy exit from the platform were non-actionable isolated or temporary conditions as a matter of law. Because we agree with the district court's conclusion, we affirm the grant of summary judgment to the City of Lafayette.