Northern District of California Decides Interesting ADA/Taxi Medallion Case

On June 30 -- though I just came across it today -- Judge Jeffrey White of the U.S. District Court for the Northern District of California granted summary judgment to the defendant in Sloane v. Taxi Commission, City and County of San Francisco. The plaintiffs, cab drivers who acquired disabilities that prevented them from working regularly as cab drivers anymore, sued under Title II of the ADA to seek modification of San Francisco's requirement that the holders of taxi medallions also be full-time cab drivers. San Francisco had adopted this requirement as part of an overhaul of its taxi medallion system in 1978. Unlike in cities like New York, where a taxi medallion is a transferrable (and very valuable) piece of property. in post-1978 San Francisco, medallion holders are forbidden to sell or transfer their medallions. Instead, taxi medallions are essentially licenses granted by the city to full-time drivers, and when a driver can no longer use the license, the city will grant it to whomever is next on the waiting list. The idea is to enrich cab drivers, not investors.

The city granted waivers of the full-time driver requirement for individuals with health conditions that temporarily prevented them from driving. But it argued that granting such a waiver to individuals with long-term disabilities would fundamentally alter the city's taxi medallion program by transforming it from a license to work to a program of disability insurance. The district court agreed and granted summary judgment to the city.