A federal appeals court has reversed the dismissal of a pro se lawsuit filed by a woman with ADHD and dyslexia against the Law School Admission Council for denying her accommodations for LSAT testing.

The U.S. Court of Appeals for the Third Circuit overturned U.S. District Judge Nitza I. Quinones Alejandro of the Eastern District of Pennsylvania's grant of summary judgment in favor of the LSAC, based on the judge's ruling that plaintiff Jane Doe did not prove a concrete injury under the Americans with Disabilities Act.

Doe requested accommodations for testing but could not provide records from her time in school in the 1980s, since they had been destroyed, and could not afford a $5,000 diagnostic report to serve as proof of her disabilities.

"Doe's allegations show that her alleged injury is concrete, not speculative," Third Circuit Judge Stephanos Bibas wrote in the court's Nov. 1 opinion. "First, Doe's request for 'accommodated testing at the next available testing date' and her statement that it is her 'lifelong dream' to become a lawyer show that she plans to take some future LSAT with accommodations."

Bibas continued, "And when she does apply for accommodations, we know what will happen because it has already happened several times. Because Doe cannot provide the required documents, the council will neither grant nor deny her request, as it admits is its practice. When this happens, the parties will reach a stalemate. So her claims are 'sufficiently developed' and ripe for judicial review."

In an email Monday, Doe said she wants to become a lawyer so she can fight for disabled people.

"Our disability runs in my family," she said. "People always want to take advantage of an intellectually disabled person. That [is] why I want to go to law school to stop it."

LSAC's attorney, Robert A. Burgoyne of Perkins Coie in Washington, D.C., did not respond to a request for comment.

A spokeswoman for LSAC said in an email, "In this particular case, we have been prepared to review this candidate's request for accommodations from the outset, but unfortunately she has never provided any documentation in support of her accommodation request. The Court of Appeals recognized the need for supporting documentation, in affirming the lower court's denial of the plaintiff's motion for a preliminary injunction.  We would welcome the opportunity to review any documentation that she can provide in support of her request for accommodation, and we will happily work with her to see that she receives any accommodation to which she is entitled."

Doe also requested an injunction against the LSAC in order to receive accommodations, but the lower court held that the issue was moot and that she was not likely to succeed on her claim anyway. While the Third Circuit reversed the court's ruling on mootness, it agreed Doe would not succeed in gaining an injunction.

"Doe's complaint is ripe and not moot, so the district court erred in dismissing it for lack of subject-matter jurisdiction. We will reverse and remand to let her complaint proceed. Though her preliminary-injunction motion is also not moot, she has not shown that she has a likelihood of succeeding on her claim that the council is wrongfully denying her testing accommodations," Bibas said. "So we will affirm the district court's denial of that part of her motion. But because the district court did not address Doe's challenge to the documentation policy, we will vacate and remand in part to let the district court consider this challenge in the first instance."