policy in employment matters." National Federation of the Blind v. Target Corporation National Federation of the Blind v. Target Corp. was a case where a major retailer, Target Corp., was sued because their web designers failed to design its website to enable persons with low or no vision to use it. Board of Trustees of the University of Alabama v. Garrett Board of Trustees of the University of Alabama v. Garrett was a United States Supreme Court case about Congress's enforcement powers under the Fourteenth Amendment to the Constitution. It decided that Title I of the Americans with Disabilities Act was unconstitutional insofar as it allowed private citizens to sue states for money damages. Barden v. The City of Sacramento Barden v. The City of Sacramento, filed in March 1999, claimed that the City of Sacramento failed to comply with the ADA when, while making public street improvements, it did not bring its sidewalks into compliance with the ADA. Certain issues were resolved in Federal Court. One issue, whether sidewalks were covered by the ADA, was appealed to the 9th Circuit Court of Appeals, which ruled that sidewalks were a "program" under ADA and must be made accessible to persons with disabilities. The ruling was later appealed to the U.S. Supreme Court, which refused to hear the case, letting stand the ruling of the 9th Circuit Court. Bates v. United Parcel Service, Inc Bates v. United Parcel Service, Inc (UPS; begun in 1999) was the first equal opportunity employment class action brought on behalf of Deaf and Hard of Hearing (d/Deaf/HoH) workers throughout the country concerning workplace discrimination. It established legal precedence for d/Deaf/HoH Employees and Customers to be fully covered under the ADA. Key findings included UPS failed to address communication barriers and to ensure equal conditions and opportunities for deaf employees; Deaf employees were routinely excluded from workplace information, denied opportunities for promotion, and exposed to unsafe conditions due to lack of accommodations by UPS; UPS also lacked a system to alert these employees as to emergencies, such as fires or chemical spills, to ensure that they would safely evacuate their facility; and UPS had no policy to ensure that deaf applicants and employees actually received effective communication in the workplace. The outcome was that UPS agreed to pay a $5.8 million award and agreed to a comprehensive accommodations program that was implemented in their facilities throughout the