Arwen Bird v. Lewis & Clark College Thomas Darrow, Phd Larry A. Meyers, Arwen Bird v. Lewis & Clark College Thomas Darrow, Phd Larry A. Meyers

Arwen Bird (“Bird”) appeals the judgment in favor of Lewis & Clark College and a number of school administrators (collectively, “the College”). Bird alleges, among other claims, that the College discriminated against her on the basis of disability, in violation of the Rehabilitation Act (“Rehab Act”), 29 U.S.C. § 794 et seq., and Title III of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12181 et seq. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and affirm for the following reasons.

Background

A. Factual history

Bird was a student of the College when an automobile accident left her confined to a wheelchair. Upon learning of her injury, the College rebuilt parts of the campus to make it more wheelchair-accessible. It installed ramps at Bird’s dormitory, changed its inside doors, and remodeled the bathrooms. It also reconfigured the biology labs where she worked.

In the fall of 1994, Bird applied for, and was accepted in, the College’s Spring 1996 overseas program. The program was field-based and required participants to spend much of their time exploring the Australian continent. After accepting Bird into the program, the College approached Global Education…