Under federal regulations, a City is prohibited from utilizing criteria or methods of administration that have the effect of discriminating against individuals with disabilities, or applying eligibility criteria that screen out or tend to screen out individuals with disabilities or any class of individuals with disabilities from fully and equally enjoying any service, program, or activity, unless such criteria can be shown to be necessary for the provision of the service, program, or activity being offered. 28 C.F.R. § 35.130(b)(3), (b)(8). Title II also requires that a public entity make reasonable modifications to its policies, practices, or procedures when necessary to avoid discrimination on the basis of disability, unless the public entity can demonstrate that doing so would fundamentally alter the nature of the service, program, or activity. Id. § 35.130(b)(7).
Thus, the question here is whether a significant proportion of disabled persons would be effectively prohibited from obtaining a zoning variance, due to financial constrants, and if so, then would the reduction in the cost of a zoning variance application fundamentally alter the ability of the city to process variance permits?
You may have statistics on the assent and income levels of seriously disabled persons. If those statistics show that an $800 administrative fee would effectively prohibit a significant proportion of those persons to obtain a zoning variance for a reasonable accommodation to their property, then you have a case against the city, and you may want to consider complaining to the U.S. Department of Justice (or, hire a private lawyer to sue on your client's behalf).
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