LAW REVIEW In the case of Griffin v. City of Los Ange-les , Plaintiffs brought a class action seeking declaratory and injunctive relief against the Defen-dant City of Los Angeles. ADA Accessibility in New and Renovated Park Facilities By James C. Kozlowski, J.D., Ph.D. I n the case of Griffin v. City of Los Angeles , 2025 U.S. Dist. LEXIS 250262 (C.D Cal. 11/13/2025), Plaintiffs brought a class action seek-ing declaratory and injunctive relief against the Defendant City of Los Angeles (the City). In their complaint, Plaintiffs alleged the De-fendant City of Los Angeles “systemically failed to ensure its newly con-structed and renovated public parks and park facilities are readily accessible to persons with mobility disabilities.” As a result, Plaintiffs claimed the City’s “allegedly deficient policies, procedures, and practices violated Title II of the Americans with Disabilities Act of 1990 (ADA).” The federal district court certi-fied Plaintiffs’ class action to in-clude “all persons with mobility disabilities, including those who use wheelchairs, scooters, canes or other mobility aids, who use or de-sire to use the City of Los Angeles’ public parks and park facilities.” In so doing, the federal district court found this class of Plaintiffs with mobility disabilities had established legal standing to pursue their ADA claims based upon alleged barriers attributable to Defendant’s deficient policies, procedures and practices, which denied them full and equal access to Defendant’s parks. ADA Title II As cited by the federal district court, Title II of the ADA pro-hibits discrimination on the ba-sis of a disability in “the services, programs, or activities of a public entity.” 42 U.S.C. § 12132. In ad-dition, the court found the ADA’s implementing regulations provided the following: [N]o qualified individual with a disability shall, because a pub-lic entity’s facilities are inaccessi-ble to or unusable by individuals with disabilities, be excluded from participation in, or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any public entity. 28 C.F.R. § 35.149. In “defining accessibility,” the federal district court noted: “Title 28 Parks & Recreation | APRIL 2026 | PARKSANDRECREATION.ORG
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