context: This court recently declined to extend the ADA to encompass failure to train liability in similar circumstances.
citation_a.signal: see
citation_a.identifier: 474 F.3d 523, 527
citation_a.parenthetical: "It was not the City's failure to train its officers, but [the deceased's] apparent attempt to run over the officers that precipitated the shooting."
citation_a.sentence: See Sanders v. City of Minneapolis, 474 F.3d 523, 527 (8th Cir.2007) (“It was not the City’s failure to train its officers, but [the deceased’s] apparent attempt to run over the officers that precipitated the shooting.”); see also Hainze v. Richards, 207 F.3d 795, 801 (5th Cir.2000) (“Title II [of the ADA] does not apply to an officer’s on-the-street responses to reported disturbances or other similar incidents, whether or not those calls involve subjects with mental disabilities, prior to the officer’s securing the scene and ensuring that there is no threat to human life.”).
citation_b.signal: but see
citation_b.parenthetical: relying on the statutory history and remedial nature of the ADA to permit plaintiff to state claim under the ADA for failure to train police and modify police practices to accommodate for mentally ill subjects of involuntary commitment warrants
citation_b.sentence: But see Schorr v. Borough of Lemoyne, 243 F.Supp.2d 232 (M.D.Pa.2003) (relying on the statutory history and remedial nature of the ADA to permit plaintiff to state claim under the ADA for failure to train police and modify police practices to accommodate for mentally ill subjects of involuntary commitment warrants).