of a public entity, defendant VSP is entitled to judgment as a matter of law. In the context of arrests, courts have generally recognized, and distinguished, two types of claims under Title II of the ADA: (1) a wrongful arrest claim, where police arrest a suspect based on his disability, not for any criminal activity; and (2) a claim that alleges a failure to provide reasonable accommodations, where police properly arrest a suspect but fail to reasonably accommodate his disability during the investigation or arrest, causing him to suffer greater injury or indignity than other arrestees. Waller ex rel. Estate of Hunt v. Danville, VA., 556 F.3d 171 (4th Cir.2009); Gohier v. Enright, 186 F.3d 1216, 1220-21 (10th Cir.1999); see also Gorman v. Bartch, 152 F.3d 907, 912-13 (8th Cir.1998) (<HOLDING>). A. Claim of Arrest for Reasons of Disability
holding that once a reasonable accommodation is made the employer has fulfilled its obligation under the ada holding that the disabled individual bears the initial burden of proposing an accommodation and showing that that accommodation is objectively reasonable and that the defendant was entitled to prevail because the plaintiffs proposed accommodation of remaining on unpaid medical leave until another customer service or receptionist position opened up was not a reasonable accommodation under the ada holding that an employer is not liable where it takes reasonable steps to provide an accommodation and the employee is responsible for a breakdown in the process of identifying a reasonable accommodation holding that a paraplegic arrestee could make out a reasonable accommodation claim under the ada after being injured in a police van not equipped with wheelchair restraints holding ada claim was discharged