Section 504 of the Rehabilitation Act of 1973, Pub. L. No. 93-112, 87 Stat. 394 (Sept. 26, 1973), codified at 29 U.S.C. § 701 et seq., is American legislation that guarantees certain rights to disabled people. It was one of the first U.S. federal civil rights laws offering protection for people with disabilities. It set precedents for subsequent legislation for people with disabilities, including the Virginians with Disabilities Act in 1985 and the Americans with Disabilities Act in 1990.
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Summary of the Section
Section 504 states (in part):
No otherwise qualified individual with a disability in the United States, as defined in section 705(20) of this title, shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance or under any program or activity conducted by any Executive agency or by the United States Postal Service.
It is codified as 29 U.S.C. 794.
As amended in 1974, Section 111, Pub L. 93-516, 88 Stat. 1619 (Dec. 7, 1974), Individuals with Disabilities are:
Any person who (a) has a physical or mental impairment which substantially limits one or more of such person's major life activities, (b) has a record of such an impairment, or (c) is regarded as having such an impairment
where
Major life activities include caring for one's self, walking, seeing, hearing, speaking, breathing, working, performing manual tasks, and learning.
However, "For purposes of employment", Qualified Individuals with Disabilities must also meet "normal and essential eligibility requirements", such that:
For purposes of employment, Qualified Individuals with Disabilities are persons who, with Reasonable Accommodation, can perform the essential functions of the job for which they have applied or have been hired to perform.
where
Reasonable Accommodation means an employer is required to take reasonable steps to accommodate [one's] disability unless it would cause the employer undue hardship.
That is, Qualified Individuals with Disabilities must be able to perform the job duties associated with the job for which they would be hired. The USA Department of Labor also indicates that "Small Providers" do not have to make "significant structural alterations to their existing facilities" to accommodate the individual with the disability.
The ADA (Americans With Disabilities Act) was passed in 1990, and seems to pick up where the Rehabilitation Act left off. Borrowing from the §504 definition of disabled person, and using the familiar three-pronged approach to eligibility (has a physical or mental impairment, a record of an impairment, or is regarded as having an impairment), the ADA applied those standards to most private sector businesses, and sought to eliminate barriers to disabled access in buildings, transportation, and communication. To a large degree, the passage of the ADA supplants the employment provisions of §504, reinforces the accessibility requirements of §504 with more specific regulations".
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Implications
Section 504 covers "any program or activity receiving federal financial assistance." If an organization receives federal support of any kind, even if the organization is not a federal or state organization, the organization must comply with Section 504. For example, airports in the United States can be at least partially funded by grants from federal and state governments, thus must be compliant. In many communities, public libraries receive federal financial assistance, directly or indirectly, so they must comply as well. Airports and public libraries became accessible according to Section 504 stipulation within a few years of the implementation of Section 504.
Requirements for educational programs
Higher education
Section 504 was the first national civil rights legislation that provided equal access for students with disabilities to higher education institutions receiving federal financial assistance. Both public and private colleges and universities supported by federal grants and funding programs must comply with Section 504. The common way higher education institutions are linked to federal funds is through the federal student aid programs. Initially, colleges, universities, and community colleges complied with the regulations imposed by Section 504 in the late-1970s and early to mid-1980s.
Higher education institutions are required to make their programs accessible to qualified students with disabilities. Qualified students with disabilities are determined by the admissions criteria of the individual higher education institution. Students wishing to receive accommodations must initiate the process, which varies per higher education institution. This process largely subscribes to the medical model of disability, as many higher education institutions require medical documentation of diagnosis and functioning regarding the disability during the accommodation application process. These colleges and universities are required to make reasonable accommodations for students with disabilities who attend their institutions.
K-12 schools
The law also pertains to any "local educational agency (as defined in section 8801 of Title 20), system of vocational education, or other school system". As applied to K-12 schools, "the language broadly prohibits the denial of public education participation, or enjoyment of the benefits offered by public school programs because of a child's disability." Although the Individuals with Disabilities Education Act (IDEA) also applies to K-12 schools, the existence of IDEA does not mean the Rehabilitation Act is superfluous. IDEA only protects a subset of children and youth who have disabilities--those who satisfy its definition for "child with a disability". The definition of disability under Section 504 is broader than that of the Individuals with Disabilities Education Act, so some children who do not meet the IDEA definition of disability are served under Section 504.
Section 504 requires school districts to provide Free Appropriate Public Education (FAPE) to children with disabilities, who may benefit from public education, within the individual district's jurisdiction. Regardless of the child's disability, the school district must identify the child's educational needs and provide any regular or special education to satisfy the child's educational needs just as well as it does for the children without disabilities. This may be accomplished by developing an education plan for the child. When done so under Section 504 of the Rehabilitation Act, it is referred to as a 504 plan. This 504 plan covers accommodations, services, and support the child will be receiving in order to have access to education at school. A 504 plan is different and less detailed than an Individualized Education Program (IEPs).
Section 504 supports rights for students for needs outside of the school day, such as extracurricular activities, sports, and after-school care, because Section 504 prohibits discrimination on the basis of disability. While the process for accommodating students varies per institution, schools generally comply with Section 504 by identifying students with disabilities and evaluating those students. If the students are eligible, they create a written accommodation plan, often called a "504 Plan." It is similar to, but often shorter than, the IDEA Individualized Education Program (IEP). Parents, teachers, and school staff are a part of the process. Parents have due process rights; where they disagree with the determinations of the school, they have a right to an impartial hearing.
Violations of Section 504 in the educational environment can be addressed locally with the education agency or with the Office for Civil Rights (OCR) of the U.S. Department of Education. Violations of Section 504 can result in a loss of the federal funding. According to the Department individuals may also file a private right of action for violations of Sec. 504. Thus, Section 504 is enforced by OCR. IDEA is carried out by another unit of the Department, the Office of Special Education Programs (OSEP).
Extracurricular activity
Section 504 covers extracurricular and after school programs such as sports, music lessons, and afterschool care. 34 C.F.R. § 104.37.
The Department of Education Office of Civil Rights has determined that Section 504 applies to:
- Playgrounds - Hazelton (Pennsylvania) Area School District, 17 EHLR 907 (OCR, March 7, 1991); San Francisco (California) Unified Sch. Dist., 23 IDELR 1200 (OCR, November 26, 1995); Mill Valley (CA) Elementary Sch. Dist., 23 IDELR 1190 (OCR, October 10, 1995);
- Band programs - Akron (Ohio) City Sch., 19 IDELR 793 (OCR, January 15, 1993);
- Special programs and assemblies - Whitman-Hanson (Massachusetts) Regional Sch. Dist., 20 IDELR 775 (OCR, August 19, 1993); Atlanta (Georgia) Pub. Sch., 16 EHLR 19 (OCR, January 9, 1989)
- Field trips and off site programs - Ontario-MontClair (California) Unified Sch. Dist., 24 IDELR 780 (OCR, February 7, 1996); Elk Grove (California) Unified Sch. Dist., 21 IDELR 941 (OCR, August 1, 1994)
- Clubs - Colquitt County (Georgia) Sch. Dist., 25 IDELR 244 (OCR, June 6, 1996); South Central (Indiana) Area Special Educ. Coop., 17 EHLR 248 (September 25, 1990);
- Afterschool and summer programs - Clayton (Missouri) Sch. Dist., 16 EHLR 766 (OCR, March 16, 1990); Conejo Valley (California) Unified Sch. Dist., 23 IDELR 448 (OCR, June 28, 1995);
- Graduation - Aldine (Texas) Indep. Sch. Dist., 16 EHLR 1411 (OCR, July 12, 1990); and
- Late bus transportation - Carmel Cent. (New York) Sch. Dist., 20 IDELR 1177 (OCR, September 30, 1993).
Rights under Section 504
Although not in the text of the statute, courts have held that individuals have a private right of action under Section 504. While punitive damages are not available, compensatory damages are available to plaintiffs. Arguably, these rights extend to include emotional distress damages.
In addition to its responsibility for enforcing other federal statutes prohibiting discrimination in housing, the US Department of Housing and Urban Development (HUD) has a statutory responsibility under Section 504 to ensure that individuals are not subjected to discrimination on the basis of disability by any program or activity receiving HUD assistance. Section 504 charges HUD's Office of Fair Housing and Equal Opportunity with enforcing the right of individuals to live in federally subsidized housing free from discrimination on the basis of disability. Further, Section 504 covers employment discrimination based on disability and requires HUD and HUD-assisted agencies to make reasonable accommodations for the known physical or mental limitations of an employee or qualified applicant. It covers all HUD programs except for its mortgage insurance and loan guarantee programs.
Any housing that receives federal assistance, such as Section 8 public housing, is subject to Section 504 regulations and requirements. Any person with a disability who feels himself or herself a victim of discrimination in a HUD-funded program or activity may file a complaint with HUD under Section 504. A complaint can be filed with HUD's Office of Fair Housing and Equal Opportunity. If a person with disabilities feels subject to discrimination in a housing situation that does not receive federal assistance, they can also file a complaint through the Americans with Disabilities Act and Title VIII of the Civil Rights Act.
History
The early history of federal legislation benefiting people with disabilities includes the Civilian Vocational Rehabilitation Act of 1920 (Smith-Fess Act) passed after World War I, one of the first U.S. laws that provided services for all Americans with disabilities, not just veterans with disabilities. Over the years, subsequent laws and amendments included additional vocational rehabilitation measures.
Section 504 brought the language of the Civil Rights Act of 1964 to the Rehabilitation of Act of 1973. As a law that fell within the office of Health, Education, and Welfare, this was an unlikely place for a social justice provision, yet inserting such a rights clause happened without fanfare. Working behind the scenes on what most believed was a bill related to budget, a staffer added the thirty-five words that addressed issues of discrimination related to disability. This was a departure from prevailing views that considered disability to be purely a medical condition. The law prohibited any entity receiving federal funding (such as government offices, schools, universities, hospitals, and post offices) from discriminating against someone because of a disability.
Concerned about costs and enforcement, the Nixon and Ford Administrations attempted to stall the regulations both by rewriting them and calling for further study regarding their impact if they did stay in their present form. Institutions such as universities and hospitals hoped to avoid bad publicity and huge expenses by waiting out the regulation process.
Disability rights groups, especially the American Coalition of Citizens with Disabilities (ACCD), understood the implications and advocated to keep them in place unchanged. Section 504 required another step before being implemented (and thus enforced), a signature from the Secretary of Health, Education, and Welfare (HEW). In 1975 a federal lawsuit was filed to force the agency to act. In July 1976, a federal district for Washington DC ruled that the regulations should be issued "with no further unreasonable delays." As the arrival of a new president drew near, HEW Secretary under departing President Gerald Ford, David Matthews, left them unsigned.
During his campaign, Jimmy Carter promised to change this if he was elected president. When he took office in January 1977, he too grew concerned about costs and invited Joseph Califano, the new HEW head, to study the legislation and its implications by establishing a task force that did not include representation from ACCD or anyone with a disability. Word leaked out that the 504 regulations that insisted on full integration of people with disabilities were being changed into something more akin to "separate but equal." ACCD members tried to reach President Carter, who had promised to support disability rights during a campaign speech in Warm Springs, Georgia, a significant location because it had been President FDR's wheelchair-accessible "home away from home" while he was in the White House. Carter insisted that the matter fell to Califano.
Protests across the US
By April 1977 disability activists had grown tired of waiting. Having tried multiple options, including letter-writing, lobbying, and personal pleas, they decided to call for a national protest if Califano did not sign the regulations by April 4, 1977. After Frank Bowe, head of the ACCD, failed to convince the new administration, approximately 300 protesters in Washington, DC marched outside Califano's house and then into his office demanding that he sign the regulations.
Across the country, other people with disabilities joined in, either picketing or occupying HEW regional offices. In addition to Washington D.C., protests took place in Boston, Seattle, New York, Atlanta, Philadelphia, Chicago, Dallas, and Denver. All dissipated out after officials made them disperse or waited them out. In Washington DC, protesters held out for 26 hours that included a standoff between them at Califano who claimed on top of a table to say that the regulations needed further study. In New York another six protesters had to leave due to lack of food and medications.
The San Francisco 504 Occupation
In San Francisco over the previous years, organizers Judy Heumann and Kitty Cone had been laying the groundwork among local organizations, community members, and people with disabilities themselves to educate them about the law and its significance. Heumann and Cone realized they needed to plan for something bigger than protesting outside in order to put pressure on regional HEW Director Joseph Maldonado who reported to his boss in Washington, Joseph Califano. They followed the lead of student activists at the time that called for occupying administration buildings on campuses across the country.
Organizing an occupation that involved people with disabilities presented certain challenges that helped spur the decision to occupy. Due to the physical nature of their disabilities, and given the Federal Building's own physical barriers (one of the things that Section 504 was supposed to address), it was difficult to move large numbers of people with disabilities in and out of the building. This meant having to plan for a longer occupation in advance but without alerting too many participants so as to prevent law enforcement from barring entrance to the building. It worked in the occupiers' favor that there had never been such a large protest involving so many disabled people before. A prevailing view held that people with disabilities were pathetic and deserving of pity, and therefore incapable of such political actions. This same perspective made officials reluctant to risk a public relations embarrassment that would result from arresting participants.
The day after ACCD's April 4 deadline for signing the 504 regulations had passed, over 500 disabled people and their allies attended a rally on Civic Center Plaza where various speakers addressed why Califano needed to sign them. Heumann urged the crowd to "go and tell Mr. Maldonado that the government cannot steal our civil rights!" Television stations and newspapers covered the initial confrontation between the protesters and Maldonado, who appeared to have no idea about the regulations or his boss's stand in Washington.
Then approximately 150 people with disabilities and their allies streamed into the Federal Building at 50 United Nations Plaza. Occupiers included people with many different disabilities. They also included many nondisabled allies such as ASL interpreters, personal care attendants, and parents of children with disabilities. The group was primarily young and racially diverse. Unlike most other major protest movements at the time (with the exception of Women's Rights), the 504 Occupation was led by women, with queer women playing an especially prominent role.
They climbed to HEW regional director Maldonado's office on the 4th floor and refused to leave. Initially, HEW officials in San Francisco tried to remove them using similar tactics to those in other cities. But the large number of people, combined with the Bay Area's atmosphere of activism and social justice, meant that the protesters had many outside allies. A number of people with disabilities had participated in the Civil Rights Movement and anti-Vietnam war protests which allowed them to understand calls for disability rights as part of the general foment of Bay Area social movements.
Support
Organizers Kitty Cone and Judy Heumann had built networks among activists for other other causes and organizations, which was new for disability rights activism. Over months and years, they had cultivated relationships with groups such as the Black Panther Party, Glide Memorial Church, the Gay Men's Butterfly Brigade, Delancey Street, the United Farm Workers, and others. The protesters also had the support of politicians that included San Francisco Mayor George Moscone, Congressmen Philip Burton, George Miller, and Senator Alan Cranston. Georgia senator Julian Bond visited the occupation. Letters of support came from Cesar Chavez and labor unions, including the International Association of Machinists (IAM). The Salvation Army provided mattresses and blankets.
This outside support enabled the occupation to continue until the regulations were signed on April 28, 1977. Especially important was the help from the Black Panther Party which, in the spirit of its food programs, provided hot meals daily in support of fellow Panther Bradley Lomax and his assistant Chuck Jackson.
Meanwhile, support from the Mayor's office and from some HEW staff working in the building made life easier inside. The City brought in inflatable air mattresses and portable showers and had new pay phones installed after HEW officials in DC had ordered the lines to be cut.
Outside the building, hundreds of supporters held daily vigils. This kept the occupation in public view and encouraged the protesters to hold on. A few outside supporters even decided to join those inside.
Life inside
Protesters found life inside the building for 26 days both difficult and life-changing. Because of the need to keep the occupation secret at the beginning, most arrived with only a toothbrush and necessary medications. Some people with disabilities had medical needs that required special attention such as eating and taking medications at set hours and being turned at regular intervals during the night to avoid getting bedsores. Because many had entered the building without their usual care-takers, they turned to their fellow occupiers to assist them in the tasks of daily living. Blind people became attendants to quadriplegics who in turn read printed information to the blind people. This created strong bonds among the protesters and educated them about disabilities other than their own.
Occupiers found innovative ways to transform an office building into a temporary place for over one hundred people to live. For example, they used duct-tape and other materials to seal off an air conditioner in Moldonado's office to create a refrigerator for storing medications.
Committees formed that gave everyone a job related to the occupation: food, safety, clean-up, entertainment, communications/media, fundraising.
Feeding such a large group was essential to keeping the protest going. Initially some people could enter and leave the building. This made it possible for them to collect donations of money and food. Major outlets such as McDonald's and Safeway contributed in the spirit of "helping the handicapped" until it became clear that protesters were engaging in civil disobedience. Within the first few days members of the Black Panther Party arrived to volunteer to feed all of the occupiers, including Brad Lomax and Chuck Jackson. "We support you because you're asking America to change, to treat you like human beings, like you belong," one explained, "We always support people fighting for their rights." When FBI agents tried to prevent them from delivering food, the Panthers held their ground. After that, the Panthers provided hot meals each day until the end of the occupation and never asked for money.
Eight of the approximately 120 occupiers who remained in the building went on a hunger strike to underline the urgency of the cause.
Protesters celebrated Easter and Passover with a mass, a seder, and a hunt for eggs.
When the FBI began restricting entry, occupiers convinced building guards that ASL interpreters and anyone provided healthcare needed to be free to come and go. During the many hours of boredom, protesters learned enough ASL that guards allowed some to move more freely. Thus the occupation was rather fluid. Some protesters even described sneaking off to the beach.
People slept on the floor in sleeping bags and blankets that were smuggled in. Some found places under desks or at the foot of a stairway. There was an unused elevator that became a favorite place for intimate encounters. There were some issues with cleanliness, including reports of lice and crabs.
Occupiers held daily meetings in one of the larger meeting rooms to keep people informed, to run the occupation, and to make plans. Because not everyone could fit, smaller networks united by disability, being from the same city, or linked by identities such as being queer sent representatives who would report back. Each committee also reported daily on what was important. Decisions were always discussed and arrived at collectively. Care was taken to make sure that each person felt their voices had been heard.
Communicating with the outside world was challenging in an era before computers, cell phones, and fax machines, especially when HEW officials ordered the office phone lines to be turned off. The building's few pay phones quickly filled will coins as the phone company stopped coming to collect them. The occupiers became resourceful. In addition to unfurling banners out the windows, they used Deaf people inside the building to transmit messages in sign language through windows on the fourth floor to other interpreters outside on the street below. They used this way press releases got out into the public and occupiers got news of the outside world.
To pass the many hours of boredom waiting inside an office building, occupiers played cards, sang, held wheelchair races, and talked late into the night. Friendships and intimate relationships formed. Occupiers, some who had never spent time away from home before, were meeting other people with the same and different disabilities to their own. They argued and bonded and discovered people with a common sense of purpose. They also gained confidence. One young woman filmed during the occupation said, "I used to know what I would wish for. I wanted to be beautiful. I wanted to stop being a cripple. But now I know I am beautiful." Summing it up later, another participant explained: "It didn't matter if you were mentally retarded, blind or deaf. Everybody...felt, We are beautiful, we are powerful, we are strong, we are important."
"The Hearing"
As the occupation dragged on, organizers sought ways to keep morale up and media attention focused on the protest. Ten days in, they came up with the idea of working with representatives Philip Burton and George Miller to host a day-long hearing in the building so that protesters could educate America about the plight of people with disabilities. The sympathetic politicians declared the 4th floor of 50 UN Plaza "a satellite office of Congress," which brought television and newspaper reporters. As cameras rolled, dozens of protesters testified on one of several panels related to specific disabling conditions: blindness, deafness, addiction, and others. In a highly public way, people with disabilities were educating Americans about low employment rates, housing discrimination, lack of educational opportunities.
During the hearing a low-ranking HEW official sent from Washington let slip that Califano was considering making twenty-two changes to the 504 regulations. These included eliminating rules that would require hospitals and schools to provide ramps and other features for access as well as setting up special schools for disabled children rather than keeping them in mainstream schools. The official used the term "separate but equal," a fact that made them even angrier and strengthened their resolve. Disability rights leader Ed Roberts - then head of the California State Department of Rehabilitation and who visited the occupation regularly - condemned this solution, stating: "Integration is the key word: people with disabilities have to come back into our society."
Some San Francisco protesters go to Washington, DC
Two weeks into the occupation, protest leaders realized that in order to succeed, they would need more national attention. Twenty-five people reflecting racial and disability diversity was elected to travel to the nation's capitol where they would meet with groups on the east coast and put more pressure on politicians. The IAM helped raise money for airline tickets and for travel once the protesters were in Washington. In these early days of the disability rights movement, it was hard to find accessible transportation, either public or private for people who used wheelchairs. This meant they had to travel in the back of a dark U-Haul truck that had a cargo lift. They slept on the floor of a church.
In Washington, protesters had meetings with congressional representatives, a challenge at a time when many federal buildings - including the Capitol - were not accessible for people in wheelchairs. They also held candle-light vigils outside the wealthy suburban home of HEW Secretary Califano where they sang "Sign 504" to the tune of the Civil Rights Anthem "We Shall Overcome.". They even protested outside of President Jimmy Carter's church but Carter slipped out the back door. Another day they held a large rally in Lafayette Park across the street from the White House that attracted hundreds of supporters.
Success and impact of the occupation
Joseph Califano signed the regulations unchanged on April 28, 1977. In San Francisco, the occupation would last another two days, until April 30, 1977, to give the occupiers time to clean up and to allow their fellow protesters time to return from Washington so they could all leave the building together with raised fists in triumph. Some also seemed reluctant to leave the disability city, the "mini-Woodstock" they had created. The 504 Sit-in lasted a total of 25 days, and remains the longest nonviolent occupation of a federal building in U.S. history.
Protesters held a large victory rally in Civic Center Plaza where occupiers sang "We Have Overcome," then toasted with champaign and gave victory speeches. Organizer Kitty Cone captured the mood and the accomplishment by saying: "We showed strength and power and courage and commitment, that we the shut-ins or the shut-outs, that we the hidden, supposedly the frail and the weak, that we could wage a struggle at the highest level of government and win!"
Over the next several years, Section 504 was controversial because it afforded people with disabilities many rights similar to those for other minority groups in the Civil Rights Act of 1964. Throughout the Reagan administration, efforts were made to weaken Section 504. Patricia Wright and Evan Kemp, Jr. (of the Disability Rights Center) led a grassroots and lobbying campaign against this that generated more than 40,000 cards and letters. In 1984, the administration dropped its attempts to weaken Section 504; however, they did end the Social Security benefits of hundreds of thousands of disabled recipients.
The protest is considered "perhaps the single most impressive act of civil disobedience in the United States over the last quarter-century." The success ensured that disability rights would be understood to be a civil right, that disabled people could claim an identity alongside those of racial, ethnic, and gender identities. It has been described as the Stonewall of the disability rights movement because it solidified the American struggle for disability rights. The successful action showed people with disabilities to be capable of grassroots action and ongoing public protest for the first time in history. It brought together people with different disabilities to forge coalitions that would work together to draft and pass the 1990s Americans with Disabilities Act (ADA).
The protests also led Califano to sign the regulations for the 1975 Education for All Handicapped Children Act, another law awaiting a signature from the head of HEW after congress had passed it. Along with provisions from 504, this law paved the way for bringing children with disabilities into the educational mainstream, giving them access to better schooling and opportunities.
The new law provoked some resistance and backlash from organizations that complained of costs.
504 trainings
As part of the 504 victory, the federal government funded disability activists to travel across the United States to explain to people with disabilities and local officials the rights guaranteed by the law. This helped spread the disability rights movement beyond the San Francisco Bay Area.
Section 504 and the Americans with Disabilities Act (ADA)
The 504 occupation created a generation of disability rights activists and advocates who would go on to draft the Americans with Disabilities Act (ADA) of 1990. The ADA can be viewed as picking up where 504 left off, handling the more difficult, complex situations. Using Section 504 as a template, the framers of the ADA sought to extend provisions that now applied to government to much of the private sector (notably private employers, stores, hotels, and restaurants). The new law also specifically stated that the ADA would not amend or weaken Section 504. Because of being drafted based on 504, the ADA also framed disability in the context of civil rights rather than as a medical need, using terms such as "discrimination," "reasonable accommodation," and "otherwise qualified." The cross-disability coalitions forged during the 504 protests also ensured that the ADA would employ a broad definition of disability so that it could encompass a wide variety of impairment groups. Like Section 504, the ADA includes people with psychiatric disabilities, alcoholics, and recovered drug addicts (though current drug users are excluded).
Activists formed by the 504 occupation such as Patricia Wright spent the next thirteen years building relationships in Washington that would help pave the way for passing the ADA.
With thirteen years of Section 504 on the books, framers of the ADA could point to evidence that the earlier law had not led to the massive economic collapse that some had predicted. (115-6)
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