Six students (three current and three former) filed a lawsuit against Bryn Mawr College and its Board of Trustees, alleging systemic disability discrimination in violation of Title III of the Americans with Disabilities Act (ADA), as well as related state law claims and class action claims.
According to the complaint, the College maintained a pattern of denying requested accommodations, understaffing its disability support office, and arbitrarily removing or excluding students from housing and academic programs. Several students alleged that they were told to buy their own assistive technology (such as an iPad or Apple Pencil), were forced to vacate dorm rooms with little notice, or were denied basic services like access to shuttle transportation, accessible buildings, or dietary accommodations (such as adequate gluten-free food options for an autoimmune disorder). One former student claimed she would re-enroll if accommodations were granted. Others described inaccessible buildings (such as Pembroke Hall and Taylor Hall), unmet academic support needs (such as extra time on exams, reduced course load, and deadline flexibility), or unsafe living conditions. The plaintiffs asserted that these failures, both individual and systemic, denied them equal access to the College’s programs and services.
The College moved to dismiss the complaint in its entirety, arguing that the students lacked standing for many claims, failed to state claims under Title III, and improperly asserted overlapping or vague theories. The Court agreed in part, but allowed three students’ claims to move forward.
The Court first addressed standing. To establish standing, a person has to show (1) they suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision.
The Court dismissed the ADA claims brought by two former students who no longer attended Bryn Mawr and who failed to plead any intent to return. Without an intent to return, the students were not able to show they had a present injury. It also dismissed some claims from current students who alleged only past, temporary injuries (such as a twisted ankle or recovery from surgery), concluding they had not shown a likelihood of future harm.
However, one former student, De Camara, alleged she would return to Bryn Mawr if accommodations were granted, and thus had standing to seek injunctive relief. The Court allowed her claims regarding testing accommodations, priority registration, and virtual attendance tools to proceed. Similarly, current students Kachru and Bañuelos were permitted to pursue their claims regarding testing accommodations and course flexibility under Title III.
The Court dismissed the plaintiffs’ theory that the College’s failure to provide iPads and Apple Pencils constituted a denial of “auxiliary aids or services” under Title III. The claim, brought by both a former and a current student with ADHD, was based on allegations that administrators suggested the devices would help manage their attention-related challenges but refused to provide them at the College’s expense. The plaintiffs argued that these tools were necessary to ensure equal access to academic programs and should be considered auxiliary aids.
The Court disagreed, finding that iPads and Apple Pencils did not fall within the statutory or regulatory definitions of “auxiliary aids” as articulated in the ADA or in DOJ regulations. It noted that the examples provided, such as Braille materials, interpreters, and screen readers, are typically targeted at individuals with sensory, manual, or communication impairments. By contrast, the plaintiffs had not pleaded that they had impairments of that nature or explained how these general-use digital tools were tailored to overcome specific access barriers created by their disabilities. The Court emphasized that it could not find an iPad or Apple Pencil to be an auxiliary aid absent a clearer connection to the individual’s functional limitations or a recognized assistive function.
Additionally, the Court dismissed with prejudice a separate “deliberate indifference” claim, explaining that Title III of the ADA does not support such a theory. Unlike Title II, which applies to public entities and allows for damages, Title III applies to private schools and authorizes only injunctive relief. Accordingly, the claim was not legally viable.
The Court dismissed all state law breach of contract claims, finding that the plaintiffs failed to identify any specific contractual promises that had been breached. The plaintiffs alleged that the handbooks and promotional materials created a contract between them and Bryn Mawr. The Court, however, found the policies insufficient to form the basis for a viable claim. The Court reasoned that the students did not identify specific provisions that gave rise to a contract.
The Court declined to strike the class allegations at the pleading stage. It found that the named plaintiffs provided sufficient factual detail to support the requirements of numerosity, typicality, and commonality—at least enough to permit the case to proceed to a later motion for class certification. The plaintiffs alleged systemic failures in the College’s accommodation practices, supported by descriptions of multiple students with similar claims, making it plausible that a class or subclass could eventually be certified.
Ultimately, the Court allowed only a subset of claims to proceed: those related to specific accommodations for testing, course assignments, virtual attendance, and priority registration brought by De Camara, Kachru, and Bañuelos. The remaining plaintiffs were dismissed for lack of standing or failure to state a claim, but were given leave to amend several portions of the complaint.
Camara v. Bryn Mawr Coll. (E.D. Pa. Sept. 26, 2025) 2025 U.S. Dist. LEXIS 190436
Note: This decision illustrates how plaintiffs can proceed under Title III of the ADA for injunctive relief based on failures to provide effective accommodations.