Blackhouse v. Jane Doe
Annotate this CaseEli Blackhouse filed a complaint for protection from abuse against Jane Doe, alleging he was a victim of Doe's stalking and asserting that Doe's actions contributed to the deterioration of his health. Blackhouse sought an order prohibiting Doe from having any contact with him or minor children in his charge and from being at or in the vicinity of his residence, school, business, or place of employment without cause. With his complaint, Blackhouse submitted a request for reasonable accommodation, stating he was disabled and unable to be physically present in court. The district court denied Blackhouse's request for an ex parte temporary order of protection from abuse and dismissed his complaint after Blackhouse failed to appear for the final hearing. There was no indication that Blackhouse's request for reasonable accommodation was called to the court's attention or that the court otherwise reviewed it before dismissing the complaint. On appeal, the Supreme Court vacated the dismissal, holding that the district court erred by dismissing Blackhouse's complaint without first considering his request for reasonable accommodation of his claimed disability. Remanded.
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