The Michigan Court of Appeals has now said, in a published opinion, that Inkster cannot use an in-person public comment rule to shut a disabled resident out of meaningful participation. Charles Blackwell, a paralyzed resident who could not readily attend city council meetings in person, was entitled to a reasonable accommodation under Michigan’s Persons With Disabilities Civil Rights Act: his written comments had to be read aloud during the meeting, not quietly filed away in the minutes after the fact.
QuickFAQs
Read Blackwell’s written public comments aloud during city council meetings, subject to the same generally applicable rules that govern other public commenters.
No. The opinion specifically distinguished this accommodation from a demand for fully virtual meetings.
Because comments that are merely circulated or preserved in the minutes are not actually heard during the public meeting, which is where public comment has its civic force.
Because plenty of local bodies treat accessibility like an administrative inconvenience. This opinion says access has to be real, not paper-thin.
Case Information
| Case | Charles Blackwell v City of Inkster |
|---|---|
| Court | Michigan Court of Appeals |
| Docket No. | No. 372782 |
| Lower Court | Wayne Circuit Court, LC No. 24-009573-CZ |
| Decision Date | April 7, 2026 |
| Status | Published opinion affirming permanent injunction |
| Core Law | Michigan Persons With Disabilities Civil Rights Act, with the Open Meetings Act addressed as part of the city’s defense |
What Happened
Blackwell, who is paralyzed because of a spinal-cord injury, could not readily attend Inkster city council meetings in person. According to the published opinion, he asked in June 2024 for an accommodation that would allow him to submit comments by email so that a city employee could read them aloud during the meeting. Inkster did that at two meetings in June 2024. Then the city adopted an in-person-only public comment policy on July 1, 2024, and stopped.
Blackwell sued under the Persons With Disabilities Civil Rights Act, seeking injunctive relief. The trial court barred Inkster from enforcing the in-person-only rule against him and ultimately required the city to read his comments aloud during meetings. Inkster appealed. The Court of Appeals affirmed.
Finding: This case turned on something governments do all the time when they want to avoid accountability for exclusion. They preserve the appearance of process while stripping out the part that actually matters. Inkster was willing to let Blackwell’s comments exist in the record. It was not willing to let those comments function as public comment.
Why Inkster’s Workaround Failed
After the litigation began, Inkster revised its policy to allow written comments to be submitted by email seventy-two hours before each meeting. Those comments would be distributed to council members and included in the minutes. But they still would not be read aloud during the meeting. That distinction mattered.
The court made clear that this workaround did not give Blackwell the same full and equal enjoyment of public comment that nondisabled residents had. Public comment is not just archival. It is performative, contemporaneous, and public. The point is not merely that officials can read something later. The point is that the speaker is heard in the room while the meeting is happening.
That is the part local governments often try to collapse. They act as if preserving content somewhere in the system is interchangeable with actual participation. It is not.
What the Court Actually Said About the Open Meetings Act
Inkster argued that the injunction conflicted with the Open Meetings Act and imposed hardship by interfering with the city’s authority to set meeting rules. The Court of Appeals rejected that framing. The opinion states that the injunction did not require a virtual meeting and did not fundamentally alter the character of Inkster’s meetings, which remained in person and livestreamed.
That matters because the city’s defense tried to inflate a modest accommodation into a structural rewrite of the meeting itself. The court cut through that move. Reading a disabled resident’s comments aloud is not the same thing as turning a city council into a fully virtual body. It is a narrow accommodation that preserves the meeting while opening access to someone who otherwise cannot use the forum on equal terms.
What the opinion shuts down: the idea that a public body can hide behind a locally chosen procedure, call the exclusion neutral, and then pretend disability law has to yield. The Court of Appeals said the statutes can be harmonized, and in this case they were.
The Undue Hardship Problem
Inkster also argued that the requested accommodation would impose an undue hardship. But the opinion notes a problem that should sound familiar in public accountability cases: the city offered no evidence. Not weak evidence, no evidence. The court specifically noted that Inkster had twice provided the accommodation already and nothing in the record showed that doing so created hardship.
That point is bigger than this one case. Institutions routinely rely on abstract burdens, speculative disruption, and managerial discomfort as substitutes for proof. This opinion is a reminder that if a public body wants to defeat an accommodation request on hardship grounds, it has to do more than wave its hands.
Why This Case Matters
This is not just a local government accessibility dispute. It is a clean example of how process can be weaponized against participation. Officials often assume that if they create a formally neutral rule, the exclusion it produces becomes legally respectable. But disability access law exists precisely because neutral-seeming procedures can still lock people out.
The opinion also gets at something more democratic than technical compliance. Public comment is one of the few places where ordinary residents can confront government in real time, on the record, in front of neighbors and decision-makers. If a disabled resident can submit comments that are never actually heard in the meeting, then the right exists in paperwork but not in practice.
That is why this case matters beyond Inkster. It is about whether access means presence in the real civic forum, or whether governments can demote disabled participation to administrative side channels and still call it equal.
Reform question: How many local governments in Michigan still run public comment systems that look open on paper but break down the minute a disabled resident needs a practical accommodation? Inkster got sued. Plenty of other bodies have not yet been tested.
What Local Governments Should Learn From This
The lesson here is not complicated. If a public body has already provided an accommodation without difficulty, it should think very carefully before withdrawing it and trying to relabel exclusion as policy. It should also stop confusing record preservation with equal access. Those are not the same thing.
Just as important, accessibility should not depend on whether a particular resident is persistent enough to file suit. Accommodation protocols for public comment should be written in advance, communicated clearly, and designed around meaningful participation, not minimum compliance.
Sources
Bluebook: Williams, Rita. Inkster Could Not Use Procedure to Erase Access: Why a Michigan Court Ordered a Disabled Resident’s Comments Read Aloud, Clutch Justice (Apr. 13, 2026), https://clutchjustice.com/2026/04/13/inkster-public-comment-disability-accommodation/.
APA 7: Williams, R. (2026, April 13). Inkster could not use procedure to erase access: Why a Michigan court ordered a disabled resident’s comments read aloud. Clutch Justice. https://clutchjustice.com/2026/04/13/inkster-public-comment-disability-accommodation/
MLA 9: Williams, Rita. “Inkster Could Not Use Procedure to Erase Access: Why a Michigan Court Ordered a Disabled Resident’s Comments Read Aloud.” Clutch Justice, 13 Apr. 2026, clutchjustice.com/2026/04/13/inkster-public-comment-disability-accommodation/.
Chicago: Williams, Rita. “Inkster Could Not Use Procedure to Erase Access: Why a Michigan Court Ordered a Disabled Resident’s Comments Read Aloud.” Clutch Justice, April 13, 2026. https://clutchjustice.com/2026/04/13/inkster-public-comment-disability-accommodation/.
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