University of Texas v. Camenisch
Headline: Disability-access ruling vacates appeals court injunction decision and sends interpreter-payment dispute back to trial, finding a temporary court order moot after the university already provided services and the student graduated.
Holding: The Court held that the appeal over a temporary injunction requiring the University to pay for a sign-language interpreter was moot because the injunction had been fully carried out, vacated the appeals court judgment, and remanded for trial.
- Students must pursue full trials to resolve who must pay for interpreter services.
- Temporary court orders that are fully satisfied can be declared moot on appeal.
- Universities may still face lawsuits over payment for disability accommodations at trial.
Summary
Background
A deaf graduate student sued the University of Texas under the federal disability law (Section 504) after the school refused to pay for a sign-language interpreter. A federal district court issued a temporary order requiring the University to pay for an interpreter while the case proceeded, and the student posted a bond. The Court of Appeals affirmed the temporary order, but by then the University had complied and the student had graduated, raising the question whether the appeal about the temporary order was now moot.
Reasoning
The Court addressed whether an appeal of a temporary (preliminary) court order remains a live controversy when the order has been fully carried out. The Justices explained that preliminary orders are meant to preserve positions until a full trial and are based on quicker, less complete procedures than a final trial. Because the injunction had been fully executed and no final trial had occurred, the specific question about the temporary order was moot. The Court therefore vacated the Court of Appeals’ judgment about the injunction and sent the case back to the trial court to decide the underlying dispute about who must pay for the interpreter.
Real world impact
The decision does not decide whether the University must pay; that question must be resolved at a full trial. Students, universities, and agencies that provide disability services should expect disputes over payment and responsibility to be decided on the merits in trial courts when temporary orders expire or are fully satisfied. The ruling keeps open the right to a full hearing before any final determination is made.
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