The U.S. 3^rd Circuit Court remanded the case of Cochran vs. Pinchak back to the district court stating that there is ample evidence to support that States have engaged in a history and practice of discrimination against persons with disabilities and disabled prisoners. Oliver Cochran is a legally blind inmate, who has been confined in several prisons in the New Jersey State Penal System. Cochran sued the State Penal System alleging that he was discriminated against when he was denied his cane, prompt medical treatment, access to his talking watch and books on tape. The District Court granted summary judgment to the State and Cochran subsequently appealed the decision. The 3^rd Circuit ruled that Cochran had presented a case that had elements that made it congruent with those presented in the case of Lane vs. Tennessee and that the remedies afforded persons with disabilities under Title II of the ADA are applicable.

In the case of Nancy Kratzer vs. Rockwell Collins the U.S. 8^th Circuit Court of Appeals ruled that the plaintiff failed to prove that her employer did not engage in the informal interactive process. Kratzer worked as a sheet metal fabricator when she suffered a work related knee injury that severely restricted her ability to stand and ambulate. Kratzer informed her employer that she wanted to take the written and four-part performance test that was required to be promoted from her current position. In a meeting on May 8, 2000 accommodations were discussed by Kratzer with management that would allow her to operate the four machines required in the performance evaluations. Based upon her current restrictions and other undisclosed impairments Kratzer did not feel the accommodations would be effective and it was agreed that an update of her medical records and restrictions were needed in order to determine what accommodations should be put into place. Kratzer did not provide the updated restriction information until July 2002. The court ruled that Kratzer's failure to provide the updated information could be considered a unilateral abandoning of the informal interactive process.