520 U.S. 1, 5 (1997) (citation omitted). Moreover, the statutory text contains no v. Gonzales, that could cast the coverage of law enforcement entities 524 “exception ” “into doubt.” Yeskey, U.S. at 209. Accordingly, law enforcement agencies fall within the comprehensive ADA’s definition of a public entity. The statutory text further demonstrates that law enforcement entities are subject to Title antidiscrimination mandate with respect to all of their operations, including arrests. The II’s reference to programs, or 42 U.S.C. § 12132, is an all-inclusive phrase that “services, activities,” covers everything a public entity does. See, e.g., The Random House Dictionary of the English 20 (2d ed. 1987) as specific deed, action, function, or sphere of Language (defining “activity” “a 1812 (1986) (defining as Third New International Dictionary action”); Webster’s “program” “a plan of procedure: a schedule or system under which action may be taken toward a desired Congress expressly defined the term or in Section 504 of goal”). Notably, “[p]rogram activity” the Rehabilitation Act of 1973, 29 U.S.C. § 701 which served as the model for Title II, to et seq., all of the operations of a covered entity. 29 U.S.C. § 794(b). Because Congress See “mean[ ] ” directed that Title II should not construed to apply a lesser standard than the standards “be Section 504, 42 U.S.C. § 12201(a), the phrase programs, or applied under” “service, activities” carries a similarly broad meaning under the ADA. 524 U.S. at 631-32. The statute See Bragdon, further protects individuals with disabilities from being to 42 U.S.C. “subjected discrimination,” § 12132, which can occur during any aspect of an interaction with a public entity. individual’s The statute therefore extends to all law enforcement operations, including arrests. The legislative history confirms that Congress contemplated that Title II would apply to law enforcement operations generally, and to arrests in particular. The House Report specified that Title anti-discrimination mandate would ] . . . to actions of state and local all II’s “extend[
v. Gonzales, 520 U.S. 1, 5 (1997) (citation omitted). Moreover, the statutory text contains no “exception that could cast the coverage of ” law enforcement entities “into doubt.” Yeskey, 524 U.S. at 209. Accordingly, law enforcement agencies fall within the ADA’s comprehensive definition of a public entity. The statutory text further demonstrates that law enforcement entities are subject to Title II’s antidiscrimination mandate with respect to all of their operations, including arrests. The reference to “services, programs, or activities,” 42 U.S.C. § 12132, is an all-inclusive phrase that covers everything a public entity does. See, e.g., The Random House Dictionary of the English Language 20 (2d ed. 1987) (defining “activity” as “a specific deed, action, function, or sphere of action”); Webster’s Third New International Dictionary 1812 (1986) (defining “program” as “a plan of procedure: a schedule or system under which action may be taken toward a desired goal”). Notably, Congress expressly defined the term “[p]rogram or activity” in Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 701 et seq., which served as the model for Title II, to “mean[ ] all of the operations of ” a covered entity. See 29 U.S.C. § 794(b). Because Congress directed that Title II should not “be construed to apply a lesser standard than the standards applied under” Section 504, 42 U.S.C. § 12201(a), the phrase “service, programs, or activities” carries a similarly broad meaning under the ADA. See Bragdon, 524 U.S. at 631-32. The statute further protects individuals with disabilities from being “subjected to discrimination,” 42 U.S.C. § 12132, which can occur during any aspect of an individual’s interaction with a public entity. The statute therefore extends to all law enforcement operations, including arrests. The legislative history confirms that Congress contemplated that Title II would apply to law enforcement operations generally, and to arrests in particular. The House Report specified that Title II’s anti-discrimination mandate would “extend[ ] . . . to all actions of state and local
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