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Demand to Stop the Unlawful Discrimination Against Individuals with Disabilities <br />and Request for Reasonable Accommodation <br />Page 6 of 11 <br />for 17 years and housed for 15 years. But K.P. still continues to visit the center <br />to help manage the symptoms of her disabilities and the case managers <br />continue to help her if she needs additional services. Without the center, K.P.'s <br />disabilities would be severely aggravated. <br />Summary of Relevant Laws <br />A. Violation of the Americans with Disabilities Act (ADA) <br />Our clients are people with mental health disabilities who are longtime <br />residents of Orange County and who are currently experiencing homelessness. <br />As such, the South Main Street Site is a crucial resource for our clients <br />because they can manage the symptoms of their disabilities by having access <br />to necessary mental health treatment, including medication and therapy <br />services, to address their disabilities. In addition, to maintain their mental <br />health, individuals are able to have their life -sustaining needs met by the Site's <br />services that allows individuals to store essential property, access to accessible <br />shower facilities, laundry services, and accessible bathrooms. Without the <br />South Main Street Site, our clients would lose access to crucial mental health <br />services and their mental health stability would be placed at risk. <br />Not only are the City's attempts to shut down the South Main Street Site a <br />disservice to people with mental health disabilities in the Orange County <br />community, but they also constitute unlawful discrimination — both through <br />intent and effect — under federal and state laws. Specifically, the Americans <br />with Disabilities Act, Section 504 of the Rehabilitation Act, Civil Code §§51 and <br />54, and Government Code § 11135. These laws require that the City provide <br />meaningful and equal access to its "services, programs, or activities" and <br />prohibit it from engaging in discrimination on the basis of disability, whether <br />through intent or actual effect. 42 U.S.C. § 12132; 29 U.S.C. § 794; 28 C.F.R. § <br />35.130(b)(1); 28 C.F.R. § 35.130(b)(8); Civ. Code § 51(f); Civ. Code § 54(a); <br />Gov't Code § 11135. <br />In seeking to shut down the South Main Street Site, the City is discriminating <br />against our clients by denying them the benefits of the services provided by <br />one of the only facilities in Orange County that is tailored to meet the needs of <br />people with mental health disabilities. Without this critical institution, people <br />