Disabled-rights activists sued the state of New York over an environmental law prohibiting motorized vehicles from most of the three million acres of the Catskill and Adirondack state parks, thus preventing them from accessing the parks with ATVs. Several influential environmental groups joined in defense of the state against the disabled.

District court judge Lawrence Kahn ruled that the case can proceed only if it focuses on individual state bureaucrats for alleged violations of the Americans with Disabilities Act. Otherwise, the state "may seek to take advantage of a sovereign immunity or state's-rights defense to avoid accountability in federal court for violations of federal civil-rights laws, environmental laws and safety or health laws, among other areas."

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