Structural barriers preventing wheelchair access allegedly prevented a Niagara Frontier Transit Authority paratransit vehicle from unloading plaintiff Jerry Moore at the main entrance to a federal courthouse in Buffalo.

Claims under Title II and III of the Americans with Disabilities Act were dismissed against the General Services Administration, but claims against New York State’s Transportation Department (NYSDOT) for violations of the ADA and Section 504 of the Rehabilitation Act were permitted to proceed to service.