Bailey

I. BACKGROUND

25 A. Factual Allegations 26 Bailey is a deaf individual who primarily communicates in American Sign 27 Language (“ASL”). Compl. at 4. On September 1, 2021, MDUSD hired Bailey to teach ASL at Concord High School. Id. MDUSD knew about Bailey’s deafness before hiring him. Id. Within a week of beginning his teaching role, Bailey requested an ASL interpreter. Id. MDUSD’s human resources department (“HR”) “repeatedly ignored or mishandled” his request for an interpreter. Id. At some point after his initial request for an interpreter, HR denied Bailey’s request citing “budget constraints.” Id. In January 2022, four months after his initial request for an accommodation, HR informed Bailey that it recognized his disability and would discuss accommodations. Id. These discussions were “unproductive and ended abruptly” because MDUSD’s staff was unwilling to provide accommodations for Bailey’s recognized need for ASL communication. Id. MDUSD’s staff stated that it prioritized providing interpreters for students over providing one for Bailey. Id. at 5. Later in the school year, MDUSD provided Bailey…