Crawford v. Prince George's County Schools - ADA Claim Affirmed

4th Circuit Daily Opinions

Filed March 4th, 2026

Detected March 5th, 2026

Summary

The Fourth Circuit Court of Appeals affirmed a district court's decision granting summary judgment to Prince George's County Public Schools in a failure-to-accommodate claim under the Americans with Disabilities Act. The court denied a motion to dismiss the appeal as untimely, finding excusable neglect for an extension.

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What changed

The Fourth Circuit Court of Appeals affirmed the district court's grant of summary judgment to Prince George's County Public Schools and the Board of Education in a case brought by Marla Crawford under the Americans with Disabilities Act (ADA). The appeal concerned a failure-to-accommodate claim. The court denied the defendants' motion to dismiss the appeal as untimely, having previously remanded to the district court to determine if Crawford could establish grounds for an extension of the appeal period, which the district court found she did based on excusable neglect.

This decision affirms the lower court's ruling and has no immediate compliance implications for regulated entities beyond reinforcing the importance of proper procedural adherence in ADA claims. The ruling is unpublished and therefore not binding precedent in the circuit, but it signifies the appellate court's agreement with the district court's assessment of the case. No new actions or deadlines are imposed by this opinion.

Source document (simplified)

UNPUBLISHED UNITED STATES COURT OF AP PEALS FOR THE FOURTH CIRCUIT No. 25 - 1196 MARLA F. CRAWF ORD, Plaintiff - Appellant, v. PRINCE G EORGE ’ S COU NTY PUBLIC SCHOOLS; PRINCE GEO RGE ’ S COUNTY BOA RD OF EDUC ATION, Defendants - Appellees. Appeal from the United States District C ourt for the District of Mary land, at Greenbelt. Theodore D. Chuang, District Judge. (8:22 - cv - 02669 - TDC) Submitted: March 2, 20 26 Decided: March 4, 2026 Before NIEMEYER, AGE E, and HEYTE NS, Circuit Judges. Affirmed by unpublished per curiam opinion. Marla Crawford, Appellant Pro Se. Ed mund J. O’Meally, PESSIN KATZ LAW, P. A., Towson, Maryland, for Appellee s. Unpublished opinions are not binding p recedent in this circuit.

2 PER CURIAM: Marla Crawford appeals the district court’s order g ranting Defendant summary judgment on Crawford’s failure - to - accommodate claim, brought pursuant to the American with Disabilities Act, 42 U.S.C. §§ 1 2101 to 12213. * We have reviewed th e record and find no reversible error. Accord ingly, we affirm the district cou rt’s order. Crawford v. Prince George’s Cnty. Bd. of Educ., No. 8:22 - cv - 02669 - TDC (D. Md. Dec. 23, 202 4). We dispense with oral argument because the facts and legal contentions are adequately presented in the materials befo re this court and argument w ould not aid the decisional process. AFFIRMED * Defendant has filed a motion to dismiss the appeal as untimely. We previously remanded this matter to the d istrict court to determine whether Crawfo rd could establish grounds for an extension of th e appeal period. The district court found that Crawfo rd established excusable neglect warranting an extension. We therefore deny Defendant’s motion to dismiss.