Who made disability civil rights law? And how did disability civil rights law, in turn, shape its subjects? This article is about what followed from the enactment of Section 504 of the Rehabilitation Act of 1973, 3 which disability rights advocates understood as their inaugural civil rights law and which became a template for the better-known Americans with Disabilities Act (1990) ("ADA"). 4 Specifically, this article recounts the history of the "Section 504 trainings," a series of government-funded convenings held all over the country in the late 1970s and early 1980s. The Berkeley-based Center for Independent Living ("CIL") ran many of them, through a legal arm that eventually became the Disability Rights Education and Law Center ("DREDF"). In doing so, the organization taught thousands of disabled people to think about Section 504 in a capacious, affirmative way. CIL trainers also used these convenings to try to affect participants' understanding of disability and its role in their lives.

For starters, trainers taught trainees that they were rights-holders. Section 504 was essentially the disability analog to Title VI of the 1964 Civil Rights Act, meaning that it articulated a right to non-discrimination in all federally funded programs and activities. That guarantee implicated vast swaths of activity: approximately 16,000 school systems, 7,000 hospitals, 6,700 nursing homes and home health agencies, 2,600 institutions of higher education, and hundreds of daycare centers, libraries, and state and local governmental agencies. 5 For people with disabilities, Section 504 arguably signaled a stunning change in status—a departure from legal frameworks that had cast them primarily as patients, wards, deviants, and charity cases.

Trainers also taught realistic techniques for vindicating those rights. In the words of one disabled lawyer and organizer from this era, Section 504 was "the first real civil rights law that people [with disabilities] could use to make change," and these trainings showed them how. 6

By the fall of 1980, CIL claimed to have trained over 1,300 "consumer specialists" across the western states, including many people who had no previous connection to CIL or its disability advocacy work. 7 Subsequent trainings in other parts of the country produced thousands more. (CIL conducted many of these trainings, but the effort also involved other organizations, including the Public Interest Law Center of Philadelphia ("PILCOP"), which had a thriving civil rights practice; the American Coalition of Citizens with Disabilities, which eventually took over the PILCOP training program; and the North Carolina-based Barrier Free Environments, led by universal design pioneer Ron Mace.) By the end of the trainings, in 1982, the grand total of trainees was around 25,000, according to one estimate. 8

This article uses archival sources, supplemented with interviews, to try to reconstruct these trainings and evaluate their significance. I drew most heavily on the archival records of CIL, DREDF, and former CIL/DREDF personnel. These records include applications for government funding; communications with federal government handlers; materials distributed to participants; audio recordings of training sessions; lists of trainees; and much more. To get a sense of whether the CIL/DREDF Section 504 trainings were distinct from other Section 504 trainings, I also consulted the records of PILCOP and Barrier Free Environments.

To capture individual perspectives, I drew on the work of the Disability Rights and Independent Living Movement Oral History Project, 9 as well as published oral histories and memoirs, 10 and then supplemented these findings with my own interviews. I interviewed ten people who worked for CIL at the time of the trainings, including eight who were directly involved in the design or administration of the trainings. To gather the federal government perspective on the trainings, I spoke with six mid- and high-level government administrators, two of whom worked at the regional level and observed trainings firsthand. I also interviewed a number of trainees: five chosen at random and two who came to my attention in other ways. 11 This sample is admittedly too small to support broad generalizations and is also biased in other ways: it consists of people who survived decades after their training date, who were relatively easy to track down, and who affirmatively wanted to speak with me. But these conversations nonetheless offer a range of perspectives on what the trainings felt like, and meant, to the people they targeted. I do not quote directly from all of these interviews, but each conversation informed my interpretation of the trainings' significance.

That interpretation has several facets. I argue, first, that these trainings affected political and legal engagement—at the national level, but perhaps even more significantly, at the local level. The individual and collective power of trainees helped initiate change and also prevented backsliding. Second, I argue that the trainings affected how at least some participants thought about themselves, as individuals, as members of communities, and in relation to government. This effect is hard to show, and was clearly not part of every trainee's experience, but appears too frequently in the sources to discount. I conclude on a less sanguine note: although there is much to celebrate in this history, these trainings are implicated in a larger architecture of disability rights enforcement that too often claims the labor of disabled individuals only to perpetuate their exclusion and subordination.

The Birth and Early Life of Section 504

In American legal and political history, the year 1973 is a big one: the Watergate Scandal, the stand-off at Wounded Knee, the abortion decision Roe v. Wade. Less visibly but as importantly, a revolution in disability law was underway. As a rich literature has documented, attention to intellectual disability had been growing for some time, thanks in part to the Kennedy administration's embrace of the issue. Parents groups had also raised the salience of disability, by demanding opportunities for children who had been excluded from school on account of physical and mental differences. Meanwhile, dramatic exposés of institutions and asylums had made the public alert to the kinds of abuses that occurred in those settings, raising questions about residents' legal and human rights. 12

Demographics contributed to this ferment. The late 1960s and early 1970s were a coming-of-age time for thousands of children who contracted and survived polio during the great outbreak of the mid-twentieth century (before the widespread use of the polio vaccine) and who continued to live with the disease's effects. As these survivors matured into adulthood and witnessed the assaults on various axes of exclusion (race, gender), new possibilities opened up before them. 13 Alongside these polio survivors were legions of disabled veterans—the result of decades of mass warfare and life-saving advances in field medicine. In short, people with disabilities were more visible, and more visibly deserving of attention, than ever before.

The Rehabilitation Act of 1973 was both a sign of disability's growing importance and a catalyst for further change. Under the Act, new streams of funds went toward the rehabilitation and vocational training of people with disabilities. Through work and independence, the Act implied, the lucky ones could return to an able-bodied standard of normalcy. 14

Buried at the very end of the Act, however, under the Title "Miscellaneous," was a provision with more radical potential—a guarantee of inclusion and access, with the power of the federal purse behind it. In Section 504, Congress declared that "[n]o otherwise qualified handicapped individual in the United States . . . shall, solely by reason of his handicap, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance." 15

Phrased differently, Section 504 appeared to do for disability what Title VI of the Civil Rights Act of 1964 (controversially) did for race. These provisions targeted recipients of federal funds and tethered continued receipt of those funds to non-discrimination. At a time when federal money infused nearly every aspect of American governance, these were no small demands. Functionally, these provisions were anti-discrimination mandates for K-12 public schools, almost all colleges and universities, many health care providers, and many state and local agencies, ranging from libraries to transit operations. And although these provisions asked nothing of "private" actors (i.e., individuals and institutions that did not receive federal funds), they had the potential to shift the terrain for everyone, by changing common-sense understandings of what was possible and what was just.

How such a guarantee became law, with such little controversy, is a fascinating story, well told elsewhere. 16 What matters for the purposes of this article is that Section 504 did become law. And then for years, the law went underenforced, tied up inside the administrative state.

Behind the scenes, key federal administrators were sympathetic to the law's intended beneficiaries. Officials in the Department of Health, Education, and Welfare ("HEW")—specifically, that agency's Office for Civil Rights ("OCR")—had successfully claimed the task of writing government-wide regulations, thus protecting the law from less supportive regulators. 17 And by 1975, OCR lawyers had drafted a relatively strong set of regulations, drawing on conversations that OCR had initiated with different disability-based organizations around the country. 18 In general, these regulations foregrounded the disabled individual's interest in inclusion and downplayed cost, 19 even amidst economic stagnation and a rising discourse of austerity. 20 As OCR's John Wodatch put it, "you didn't tell . . . African Americans that it costs too much to integrate their schools. You're not going to tell a disabled person it costs too much to get them a sign language interpreter for their class." 21

The regulations also interpreted Section 504's non-discrimination language to require more than formally equal treatment—that is, not just eradicating policies of formal exclusion but also changing structures and practices that non-disabled people understood as neutral. This kind of interpretation would become integral to U.S. civil rights law, but in 1975, it was not obvious and, in fact, contradicted how some government officials understood the law. 22 Sometimes, OCR's draft regulations indicated, pursuing equality meant treating members of protected groups differently, including by granting accommodations. 23

The progressiveness of these draft regulations contributed to the years'-long delay in their formal release. HEW Secretary David Matthews came and went without taking action. His successor, Joseph Califano, seemed equally uncomfortable. As he later explained, Congress had given disabled people "an unqualified ticket to equality and opportunity," and now his agency was stuck between a "white hat"-wearing "special interest group" and some very sympathetic institutions, including resource-strapped universities and city transit systems. 24

The next chapter of the story is familiar to disability scholars and has become a touchstone of the disability rights movement. Outraged by the delay, disabled organizers and their allies spread the word about Section 504 and the bureaucratic machinery that appeared to be thwarting it. Protests followed, including dramatic sit-ins at HEW offices around the country, a federal lawsuit, and even a demonstration outside Secretary Califano's personal residence. 25 The month-long occupation of HEW's San Francisco office, in particular, is the stuff of legend. 26 On April 28, 1977, Califano signed the regulations.

But the story does not end here—or at least it shouldn't, for if it did, we would fail to see how disabled people participated in the subsequent implementation of the regulations and how that participation, in turn, affected behavior, consciousness, and the concrete meaning of this landmark law.

Contracting Out — to the "Crip Capital of the World"

Although the legislative drafters of Section 504 did not consult many people who identified as disabled, implementation brought a concrete guarantee of inclusion. By June 3, 1978, the regulations dictated, recipients of federal funds were to (1) "evaluate" their own compliance with Section 504, (2) "modify" any policies or practices that did not meet the law's requirements, and (3) remedy any discrimination identified. 27 Further, the regulations required that recipients draw on "the assistance" of people with disabilities (at step 1) and act in "consultation" with them (at steps 2 and 3). 28 In other words, the regulations required involvement of the constituency whose rights were on the line.

Although participation mandates of this kind were hardly exceptional in the 1970s, 29 and although this particular mandate had no real enforcement muscle behind it, it was nonetheless a notable development in the history of U.S. disability policy. The little-known mandate allowed HEW officials to offer hundreds of thousands of dollars in contract money for "consumer trainings" of disabled Americans. 30 (Trainees were "consumers" in the sense that they consumed the federally funded programs at issue. The word choice is also consistent with the rise of a consumption-oriented understanding of citizenship and with preferences of proponents of independent living, who rejected dependency-connoting alternatives.)31 Mere pocket change to the federal government, this money meant much more to the organizations on the receiving end.

One of those organizations was the Center for Independent Living ("CIL"), a renowned hub for disability activism and one of the reasons for Berkeley's designation as "crip capital of the world." 32 Years of labor by the disability community have ensured that CIL's history is well chronicled, especially that part that connects to the University of California, Berkeley in the 1960s. 33 At that juncture, UC Berkeley admitted students with significant physical impairments, but did not provide accessible housing. The official solution was a dorm, of sorts, on one floor of a campus hospital. As the students housed in that hospital advocated for their needs and resisted the power of rehabilitation professionals, they developed a shared consciousness, cutting across their different impairments. The students came to understand themselves not as patients or objects of charity, but as an oppressed political minority, denied their rightful opportunities. Just as federal policymakers incorporated "maximum feasible participation" into the War on Poverty, these students coalesced around the idea that disabled people knew best their own needs and should control their own lives. This advocacy eventually turned into the Physically Disabled Student Program ("PDSP"), which HEW funded as a pilot project in 1970. CIL formally took shape two years later, when it became clear that PDSP could not meet the needs of the broader disability community and when key community members were drawn to a less hierarchical organizational structure (while sharing PDSP's commitment to self-advocacy and non-institutional living). 34

For an entire cohort of leaders, CIL was a place where they developed political consciousness, amassed strategic and technical knowledge, and forged coalitions—often in the course of doing things that were simply necessary for happiness and survival: getting wheelchairs fixed, identifying job opportunities, tracking down accessible housing, learning about non-institutional forms of government support, making friends, meeting lovers. 35 By 1979, CIL's lively storefront operation on Telegraph Avenue served approximately five thousand clients. It also employed 120 people, about half of whom identified as disabled. 36

One byproduct of CIL's day-to-day activities—directly relevant to the Section 504 trainings—was expertise in law and bureaucracy. This came from staff members' countless dealings with federal, state, and local social welfare agencies, both on behalf of themselves and CIL's clients. It also grew from CIL's precarious financial footing, which meant continually applying for government grants and contracts. 37 And it arose from the pleas for justice that regularly came through the door. Eventually someone at CIL was savvy enough to connect that demand to a government-funded employment training project. (Even after the Nixon Administration undermined core elements of the Great Society, there was always money for programs that sounded like work.) By the mid-1970s, CIL paralegals-in-training were helping clients file discrimination complaints and pursue disability-based income support, 38 under the supervision of a lawyer funded by the federal Volunteers in Service to America Program (VISTA)39 (Paul Silver). The addition of one more lawyer in early 1977, Robert ("Bob") Funk, allowed the legal practice to really take off. Shortly thereafter, the initiative acquired its own name: the Disability Law Resource Center ("DLRC"). 40

Funk had arrived at CIL as "sort of a closet cripple," not "very in touch with his disability stuff," according to one close associate. Perhaps because of that, he was most enthusiastic about the legal work that emphasized equality: as citizens, disabled people and non-disabled people were fundamentally the same and so deserved access to the same public goods and services. 41 In August of 1978, when HEW began offering grants to organizations to train consumers in their rights under Section 504, the opportunity aligned perfectly with Funk's vision for DLRC.

From HEW's perspective, DLRC's application was also a good fit. The HEW officials most directly in charge of the 504 trainings understood Section 504 as a civil rights law and they wanted trainings that reflected that view. 42 Practically overnight, it seemed, $350,000 in federal funds (over $1.5 million in 2022 dollars) became available to DLRC's small staff. (Complicating matters, this was one of six government grants and contracts that DLRC won between September 1 and October 1, 1978.)43 Working out of CIL's unheated garage, and later from rented warehouse space across the street, the DLRC team scrambled to figure out how to train the promised six hundred consumers in thirteen Western states. 44

Finding Consumers: "We Beat the Bushes"

"Here we are . . . a bunch of Berkeley hippies, and we don't know anything [about training]," recalled Mary Lou Breslin, when reflecting on the training project that she oversaw. 45 In truth, though, she and her team were not out of their depth. Since September of 1977, DLRC had conducted at least fifteen training sessions for discrete audiences, ranging from state social welfare employees to university administrators. 46 And DLRC lawyers and paralegals were fully capable of mastering the legal-technical aspects of the regulations. The team also benefitted from the expertise of a Berkeley-based consultant named Alan Kalmanoff, who more or less wandered by at just the right time. 47 With ten years of experience training police officers (in how to not violate people's rights) and a borrower's eye for cutting-edge group therapy techniques, Kalmanoff had plenty of ideas about how to pull off a large-scale citizen training. 48

First, though, DLRC had to find people to train—and to find them outside of CIL's niche in Berkeley. Testing the limits of its network, DLRC sent brochures to thousands of individuals and disability-related organizations, ranging from consumer-run advocacy groups like CIL to the so-called "disease groups" that, in other contexts, CIL eschewed—groups like the National Association for Retarded Citizens (now "the Arc"), the Easter Seals, and the National Multiple Sclerosis Society. 49 As Breslin put it, "we beat the bushes." 50

It is unclear how many people expressed interest and, of those, how many DLRC turned away. There was an application, albeit a simple one: It required the candidate to fill out a form, describe a potential 504 compliance problem in their own community, and address their own strengths and weaknesses as a community organizer. 51 There was also a screening interview, suggesting that at least some candidates may have been "screened out." 52

Existing records do, at least, reveal the training group that resulted. Perhaps not surprisingly, it shared some of the characteristic of CIL itself: it was more or less balanced by gender, but majority White, and physical impairments predominated. But there were also signs that DLRC strove for, and achieved, some measure of diversity. For example, the breakdown of the five hundred Midwestern trainees in 1980-81 was reportedly 75 percent "white," 10 percent "Black," 11 percent "Native American," 2 percent "Hispanic," and 2 percent "Miscellaneous." Members of this training group identified with various types of impairment, including mobility impairment (34 percent), hearing impairment (19 percent), visual impairment (8 percent), and mental impairment (3 percent); the rest identified as "other health impaired" (13%) or non-disabled (parents or spouses of a person with a disability; some rehabilitation professionals and educators). 53

The training population was also mixed in its levels of disability awareness and expertise. Some participants, such as California trainee Vernon Cox, came with leadership experience and a history of activism. By the time of his training, Cox had persuaded two cities to make curb cuts; after the training, he founded an independent living center. 54 Trainee Clarinda Valentine, the winner of "Ms. Wheelchair Chicago 1978-79," worked for an HEW regional office at the time of her training. She later made headlines for adopting two children as a single, African-American, paraplegic woman, while maintaining a career as a social service consultant and administrator. 55 New Mexico trainee Mike Phillips had been invited to the 1977 White House Conference for Handicapped Individuals and advised a major city on accessibility issues. 56 Mary-Therese Schweickert, who attended a training in Sunnyvale, California, in 1982, did not consider herself an activist but was acquainted with Section 504 through her work in rehabilitation counseling and disabled student services. 57

By contrast, Minnesota trainee Irene Thom was a novice—open about her schizophrenia diagnosis and energetic in her volunteer activity, but not a known quantity in the world of disability rights. 58 Shelley Bergum participated in a Billings, Montana, training only months after the car accident injury that led her to identify as disabled. 59 Newspapers searches suggest that many trainees shared this more limited level of exposure to Section 504 and to the kind of pan-disability organizing that CIL represented. They were people who identified publicly with some kind of impairment, but if their name made it into the local paper, it was because of something like an unexpected feat of athletic prowess or a cheerful display of "determination," not because they had planted their bodies in front of an inaccessible bus (as some activists famously did at this time). 60

Whether a seasoned veteran or a relative newcomer, however, participants quickly learned that they were part of something bigger. By the end of 1979, the first year of trainings, DLRC had created a regional network of 1,354 trainees. 61 By 1980, a senior CIL staffer estimated that the trainings had reached 5,000 people in the West and Midwest and 8,000 in the rest of the country. 62 By the time the training program came to an end, around 1982, the network of trainees included an estimated 25,000 people. 63

"Maximum Accessibility"

"We're trying to change the world to accommodate us, instead of the other way around," a CIL representative explained in a 1978 video about the organization's approach to advocacy. 64 That philosophy animated the environments that DLRC created at the Section 504 trainings, each of which took place over three-to-four days. 65

DLRC sited the trainings in hotels, sometimes exceptionally nice ones, 66 and DLRC staffers did significant advance work to make sure that these spaces were accessible. At their insistence, toilets gained lift seats, under-sink cabinets were dismantled, and bathroom doors were modified . 67 Lighting was also sometimes adjusted, to avoid triggering trainees with epilepsy. 68 If a pre-arranged hotel could not accommodate the needs of trainees, DLRC would relocate rather than ask trainees to navigate an inadequate space. 69 Detail by detail, DLRC staffers removed the kind of barriers that made physical and mental impairments feel so disabling.

Aware that physical space was only one aspect of accessibility, the DLRC staff also made arrangements to address needs that might arise during the training itself. They hired personal attendants and interpreters, arranged complicated audio-visual equipment, and ensured that someone would be available to repair wheelchairs. 70 They even educated the hotel staff, about everything from the nature of the trainings to the importance of beverage straws. "Tell [the hotel staff] exactly who you are, what the training is about, [and] what 'civil rights' is about," instructed a checklist for the training facilitator; tell them what it means when someone says "leave me to take care of my own needs." 71 The same document included instructions to give hotel meal servers: they were to "speak directly to the disabled person, rather than some able bodied neighbor." 72 If friction developed with hotel staff, the facilitator was to "'oil' the works . . . with praise or money." 73

Taken together, these preparations amounted to promises of "maximum accessibility," in trainer Corbett O'Toole's words, and to dignified, professional treatment. "If you come," the message was, "we will get you out of bed, we will get you up in your chair, we will help you eat your lunch, we will provide sign language interpreters, we will have braille, we will have tape." 74 Further signaling trainees' value, DLRC paid for their transportation and accommodations.

Such attention and recognition was unusual for the time. Two decades after her training, Johnnie Lacy still recalled how "overwhelm[ed]" she felt when she saw the famous Claremont Hotel—"this luxurious kind of place" in California's Berkeley/Oakland hills—"being occupied by a bunch of disabled people." She also remembered how remarkable it felt to be "with a group of [disabled] people who saw themselves as people, not as objects of pity," and who "were not blaming themselves" for the obstacles they faced. 75 This, in a nutshell, was the CIL ethos: it was about combatting images of disabled people as "helpless" and "pathetic" and highlighting the ways in which society made people so, by erecting and maintaining barriers that did not need to be. 76

"You Sure as Hell Better Know What a Leg Bag Is"

As important as creating an obstacle-free environment were DLRC's training methods. One foundational choice—consistent with practices at CIL, but different from some other organizations that received training contracts—was DLRC's insistence on trainers who could be perceived as "peers" or "role models." DLRC laid the groundwork for this in 1978, when it recruited ten disabled individuals to serve as trainers: two who were vision impaired, two who identified as Deaf, and six who had "physical orthopedic disabilities." DLRC recruited an additional thirty-eight trainers in 1979, expanding the pool to include "hidden disabilities" (three trainers) and increasing the number of women (from two to sixteen) and non-White people (from one to nine). 77

The size of the trainer group ensured that a three-person team could lead every training. They were almost all conventionally attractive ("disability pretty"), trainer Corbett O'Toole recalled in 2018, and the most frequently used trainers were largely White. 78 But they did represent a variety of disabling conditions, which guaranteed a cross-disability training experience. 79 The point bears emphasizing because, outside of Berkeley, such experiences were relatively rare. To the extent that trainees were involved with disability activism prior to the training, it was likely within a tighter affinity group. For example, a blind person coalesced with other blind people, a Deaf person with other Deaf people, and so on. Cross-disability organizing remained the exception in the late 1970s, not the norm. 80 By showcasing this style of organizing and by placing people with disabilities in charge, "we modeled . . . the world we wanted to see," trainer Kathy Martinez remembers. 81

Whatever each trainer's disabling condition, that person labored to connect with the trainees. Long, personal introductions (painstakingly rehearsed) were the start. 82 Trainer Cecilia "CeCe" Weeks described the diving accident that broke her neck when she was fourteen years old and the painful adjustments that followed. 83 Trainer Susan Schapiro, paralyzed in a car accident at age sixteen, told a similar story—of suddenly feeling "like a non-person," with no right to the kind of life she had before the accident. 84 Other trainers talked about what it was like to have a disability from birth. Trainer Ann Cupolo, born with diastrophic dwarfism, described being segregated all her young life with other children with disabilities and how that affected her aspirations and self-concept. Even after she made it to college, she explained, the only career she could imagine for herself was being a piano teacher who worked inside her own home. 85 Gail Rinne, a "low vision" trainer from the South, talked about being encouraged to pass as non-disabled whenever possible. If she couldn't see something, she was supposed to "pretend [she] could," even if that meant not using the restroom when she felt the urge and flunking classes where she couldn't see the blackboard. 86

Migrating to Berkeley, in many of these narratives, was transformative. Only when she landed in Berkeley and started working for CIL, Gail Rinne explained, did she stop feeling like a "woman without a country." 87 Berkeley also changed interpretations of past experiences. It was unjust, Susan Schapiro realized, when she felt compelled to attend a high school thirty miles away from her home rather than going to her neighborhood school, where her access to classes would have depended on the school's "half-hearted[]" offer to have the janitor carry her up and down the stairs every day. 88 It was unfair, Ann Cupolo learned, for her high school to deem her "too short" to attend, unless she used a wheelchair (something she did not need at the time). 89 Similarly, Rinne gained a new language for describing why she felt wronged, back in North Carolina, when an employer fired her from a cashier job after noticing a reference on her W-2 to blindness. In Berkeley, she explained, she learned that the civil rights movement applied to her, too. 90

These narratives had purpose. Implicit in CIL's long-standing commitment to peer counseling was that if trainees could see themselves in the trainers—all of whom projected power, confidence, and satisfaction—they would develop a more positive self-image and become better able to effectuate political change in their own contexts. 91 A more pragmatic rationale was that it helped generate trainee buy-in. Consultant Alan Kalmanoff, who helped design the training program, put it this way: "if you are going to teach me about my civil rights as a disabled person, you sure as hell better know what a leg bag is." Without shared experience, he believed, trainees were less likely to "to see that the things you are bringing to the party are things that they can dance with." 92

How to Wield a Right

The main thing trainers "brought to the party" were rights, along with the posture that accompanied that concept. In the words of a 1979 report, the grounding of the training project was "the fundamental notion that disabled persons are citizens with full rights to equal opportunity." 93

Fittingly, the substantive part of the training opened with the history of Section 504—told through a particular lens. Stated in the simple language of the training curriculum, "Section 504 is part of the long history of civil rights legislation in America." That history dated back to the Bill of Rights and also included the Emancipation Proclamation, the Reconstruction Amendments, and Brown v. Board of Education (1954). 94 The message was not subtle: disabled people in the late twentieth century were an oppressed minority, not unlike enslaved people and their descendants. But finally, legal recognition and remediation had arrived.

Looking back on this framing, there is much to critique. Most obviously, by characterizing the struggle for racial equality as an antecedent or an analogy, the training implied an un-raced (or White) disabled population at last getting a taste of what Black Americans (impliedly non-disabled) had already won. From the DLRC perspective, however, this framing was helpful, for it infused the lessons that followed with a sense of righteousness and a tempered optimism.

Those subsequent lessons included an impressive amount of "black letter law," explained in colloquial style. Trainers were especially keen to alert trainees to key words and phrases in the otherwise dense regulations and to flag places where precise meaning remained up for grabs. For example, when the regulations described giving "handicapped persons equal opportunity to obtain the same result" as others, did that mean it was acceptable to send a disabled person to the most unattractive or low-status bathroom, located in the far recesses of the building? 95 Institutions would try that, trainers warned, and trainees must resist. The same lesson applied to the provision mandating that services be given in the "most integrated setting appropriate to the person's needs." People with disabilities needed to claim that word "appropriate," the trainers emphasized. "We decide what is appropriate to our needs." 96

Simultaneously, trainers sought to deny the regulations a mystical or intimidating quality. "If you don't understand [something in the law] the first time we say it, it's because none of us understood it the first time we said it or read it," assured trainer Gaile Rinne in a 1980 training. She encouraged trainees to think of law as just "Washington's verbal diarrhea that we can use and work with." 97 "[J]ust because this is the law doesn't mean that you have to be a lawyer to understand it," emphasized trainer (and former trainee) Shelley Bergum to another group. Most of the trainers, after all, weren't lawyers, and yet the government trusted them to explain it. 98

To that end, trainers budgeted much more time—21.5 of 24 hours—to skills and strategies for putting the law into action. 99 As part of the training, trainees filled out a worksheet in which they identified a HEW-funded recipient (e.g., a school, hospital, or social services program), described a 504-related problem, articulated a desired solution, and answered questions relating to strategy. 100 Later, small groups worked through one of these scenarios—for example, that of a county health clinic with no interpreters available and no electromechanical devices (such as a teletypewriter, or TTY) for allowing non-speaking clients to communicate. Drawing on the training materials and their own experiences, trainees discussed and debated possible strategies. 101 For their part, trainers interjected observations, but offered no answers, signaling that trainees knew better than outsiders how particular strategies would play out in their own communities. The only thing that trainers did insist on was that trainees, first, know their rights, and second, act like a person who had them.

One right was participatory. Referencing the "self-evaluation" language in the regulations that birthed the trainings, the 1979 training curriculum put it this way: "[Y]ou have the right to assist in making physical and policy changes to ensure continued 504 compliance." 102 Or, as trainer Gaile Rinne declared in a 1980 training session in Chicago, "This is your law. This is our law"; "[w]e are the people who make the law effective . . . ." 103 Realistically, echoed Shelley Bergum to a group of trainees in Cincinnati, Ohio, "nondisabled Washington bureaucrats . . . have very little idea" of what Section 504 means. "[T]hat's where we come in"—to explain how the law should be interpreted. 104

A second right was non-discrimination, which in practice could mean a right to accommodation. As trainers explained it, Section 504 gave disabled people the right to access all the same services and opportunities that nondisabled people enjoyed (or at least, all the services and opportunities that the federal government subsidized). This was not a guarantee of identical results or even identical treatment, trainers cautioned. But it nonetheless could have many implications, from the height of a doctor's examining table to the location of an accessible bathroom. "Don't let your employer decide what is a reasonable accommodation," emphasized trainer Steve McLelland, "You know best . . . what your needs are." 105

What trainers emphasized most of all, however, was not the specific content of rights but the need for the trainees to behave as rights-holders. Trainers called this "the rights bearing attitude"—and it was "the key to everything," in one trainer's words. 106 It provided motivation. It was armor against self-defeat. It was the foundation of effective communication. 107 "This isn't just a question that we're asking you for something," one trainer explained, during a role play exercise where she was portraying the "disabled consumer." "It's our right to have it." 108 "Ninety percent of [the trainings] was really teaching" that point, trainer Corbett O'Toole later recalled. 109

A "rights bearing attitude" was not synonymous with a "litigious attitude"—an important distinction. The trainings characterized judicial proceedings as essentially one option, often of last resort. As CIL deputy director Judith Heumann later explained, DLRC wanted trainees to know how to file legal complaints but also how to "prevent[] complaints from having to be filed," by wielding other tools of persuasion. 110 It was no coincidence that entire pages in the training curriculum came from the burgeoning world of alternative dispute resolution111 and that filing a lawsuit was not one of the exercises the trainees practiced. 112 As trainer Corbett O'Toole later recalled, "we basically said to people, 'You have rights. Go use them.' And they found ways that made sense for their communities and for themselves, individually, to [do so]." 113

Going Home – and Getting Organized

When participants left the trainings, they were different, or at least differently equipped. DLRC's "Consumer Training Curriculum" distilled for them the lessons of the previous days. A "technical reference manual," titled "The Consumer Guide to Section 504," used layperson's language to explain the ins and outs of Section 504. 114 DLRC also added trainees to the distribution list for its newsletter, Access, which tracked doctrinal and regulatory developments. 115

The message of these materials was, first, that trainees now had expert knowledge and that they should put it to use. Indeed, one of the reasons for treating trainees so professionally was to communicate this expectation. As trainer Corbett O'Toole explained it: "you're going to walk out of here being able to do your job"—and yes, trainees now had a "job," even if they had been denied access to paying jobs for their entire lives. 116 Second, DLRC trainers told trainees that now they were the trainers. Using these materials, trainees should go out and educate others. 117

Trainees also left with the assurance that they would not have to go it alone in attempting to enforce Section 504. A hotline, staffed by specialists at CIL, was available for technical assistance. DLRC also offered on-site consultations, should a complex local problem arise. 118 DLRC further institutionalized this support service in 1979, when it began funding a small number of "Technical Assistance Satellite Units" throughout the country. 119 Some of these units affirmatively reached out to all trainees in their designated area. 120 Finally, to help trainees develop their own networks, DLRC gave them a list of all the other advocates DLRC had already trained. 121

This last resource contributed to a final, less tangible, takeaway: what participant and CIL staffer Linda Gill called "the hidden agenda." In Gill's words, it was about getting "organize[d]," "becom[ing] radical," and learning to "coalesce with other folks with other disabilities." 122 In reality, this agenda was not hidden at all (and, in fact, had the approval of top federal government administrators). 123 Over the course of these sessions, trainers encouraged trainees to get to know each other, to share useful information, and to recognize their commonalities. Trainers talked frequently about the broader movement, in ways that encouraged trainees to feel part of it and build it out at the local level. 124 "In the end," recalls Mary Lou Breslin, the trainings "became a community organizing tool really. I mean that is what it really was." 125

Legacy I: Political and Legal Engagement

Breslin's comment invites questions about consequences. One consequence, according to some people involved with the trainings, was the creation of a nationwide, grassroots network for DLRC, which during this period became the Disability Rights Education and Defense Fund (DREDF) and formally separated from CIL. Over the next decade, DREDF would famously combat executive branch efforts to defang Section 504 and also help spur the enactment of the ADA.

There is ample evidence that DREDF recognized trainees as a political resource and attempted to mobilize them. In 1981, when President Ronald Reagan's task force on "regulatory relief" began targeting Section 504, and when new draft guidelines made cost the crucial determinant of Section 504's protection for civil rights, 126 DREDF sounded the alarm. The revised guidelines "DESTROY OUR RIGHTS AS CITIZENS TO EQUAL OPPORTUNITY AND EQUAL TREATMENT," DREDF warned its network. 127 "If you don't [act]," read one "action alert," "no one else will." 128

DREDF's "hidden army" responded by bombarding the task force with angry correspondence—some 40,000 letters, according to one common estimate—until Section 504 was taken off the de-regulatory agenda. 129 That "hidden army," according to Breslin, was the 504 training network. 130

DREDF called on that network again in the mid-1980s, as momentum built for a civil rights bill that would reach beyond the public sector, to private employers and businesses, 131 but in this instance, it is harder to say whether the 504 network responded or was influential. Interviewed ten years after the enactment of the ADA, Breslin had "no clue" whether DREDF's pleas for vigil-holding and letter-writing had a direct influence on lawmakers. 132

National policy landmarks are not the only consequences worth caring about, however. Evidence suggests that the 504 trainings created a broader, more diffuse legacy of political engagement. According to Deborah Kaplan, a lawyer who began her career at CIL and led some of the 504 trainings in the eastern U.S., 133 those sessions created disability leaders and infused the movement with new people. The result was "a lot of activism and energy and new coalitions and new organizations." 134 Trainer Corbett O'Toole has also characterized the trainings as motivating and energizing, even as they confirmed how "absolutely pervasive" discrimination was. 135

After the trainings, DLRC records suggest, many trainees did press for change in their communities. In October 1979, after the first year of trainings, DLRC drew on written surveys and follow-up telephone calls to tally 258 "individual projects" and 89 "team projects," in areas ranging from health to post-secondary education. 136 DLRC documented "changes in recipient behavior" in 113 cases. 137 Summarizing the activities of the consumer specialists trained in the Western region in Fiscal Year 1979-80, DLRC reported 41 instances in which trainees participated in a recipient's "self-evaluation" or "transition planning"; 34 attainments of accommodations, adjustments, or access; 7 successes in eliminating discriminatory practices by health care providers; and 5 instances in which trainees influenced the design, construction, and alteration of facilities. 138

Other DLRC records offer concrete examples. In Oak Brook, Illinois, a suburb of Chicago, a trainee reportedly initiated a conversation with the Postmaster regarding treatment of Deaf employees. One result was a "mini-training for Postal Service managers in that district." 139 In Kansas, a 1979 trainee filed a class action lawsuit on behalf of her son, who had epilepsy, and similarly situated school-age children in the state. Other trainees supported her, by forming an ad hoc committee to educate other parents about their children's civil rights. 140 In Gibson County, Indiana, a trainee organized a training of the staff of the local rehabilitation center on how to spot a violation of Section 504 and thereby better help their clients. 141

DLRC also document a range of activities that did not produce a "quantifiable change in recipient behavior" but that nonetheless evidenced grassroots organizing. For example, the consumer specialists trained in the Western region in Fiscal Year 1979-80 reported 517 instances of "coalition building"; 537 negotiations with recipient agencies; 501 reports of public speaking; 335 reports of consumer training work; and 137 instances of participation in media events. Trainees sent in an additional 103 reports of joining committees or boards. 142 After the Midwest trainings, a group of Indiana trainees formed an organization called "Deafness and 504" and began working on getting teletypewriters (TTYs) installed in fire departments, police stations, and other public offices. Trainees from Ohio, organizing under the name "the Ohio Deaf 504 Doers," did something similar. 143

Newspaper accounts lend credence to DLRC's data, while falling short of proving that the trainings caused any particular incident of activism. For example, in 1981, within two years of attending a training in Montana, Vivian Crabtree applied for a position with the public library system and sued when she was not hired. (Crabtree, according to newspapers, was "legally blind but [could] read with a magnifier"; she sought a position that involved creating audio recordings of books.) Crabtree ultimately won her case—which made it all the way to the Montana Supreme Court—after citing a state law that gave an "absolute preference" to veterans and disabled civilians. 144 Similarly, trainee Barbara Gray-Pendleton made headlines in New Mexico the year after her training: In her role as Administrator of Southwest New Mexico Services to Handicapped Children and Adults, she "staged two demonstrations" to protest the state's proposed cuts to her organization's funding. (She succeeded in preserving the funding.)145 Neither example of activism directly implicated Section 504, but both advanced the trainings' vision of an educated disabled citizenry demanding accommodation and support.

Whether such activism was commonplace or rare is harder to gauge. My interviews with seven surviving trainees suggest that they felt only loosely connected, if at all, to DREDF's subsequent organizing work. But in the months and years after their trainings, some of them drew on their knowledge of Section 504 to effect change in their local contexts.

For Shirley Jarman, a nondisabled trainee who worked in disabled student services at a university at the time of her training and was a parent advocate for a child with polio, the training and others like it gave her greater confidence when her employer balked at students' access requests. She handled many disagreements informally, and once applied for outside funds to solve an access problems (lack of an elevator in the Student Union), but she was also willing to tell colleagues, "the law's the law." If cost was the stated concern, she expressed her hope that the campus "find [the money] before a student files a lawsuit." 146

For one New Mexico trainee, a low-vision public school teacher at the time of her 1979 training, a Section 504 complaint against her school system was a "direct result" of what she learned from DLRC. Thereafter, legal complaints were a regular part of her repertoire—a tool she felt confident using even when lawyers were unsupportive. She also spread her knowledge to local outposts, such as an independent living center in a major city in the southwest. "[I]f we just have the law in one little jar, it doesn't do any good," she told me. "You have to spread it around." At age 71, she still had a binder of material from her Section 504 training. 147

Such anecdotes are a necessary complement to existing scholarly analyses of Section 504, which, in their focus on lawsuits and administrative complaints, take a dim view of the law's efficacy. 148 To fixate on these formal processes is to overlook the kind of changes that occurred at the ground level, sometimes without significant resistance: "putting in a Dixie cup dispenser" near a drinking fountain or "getting a class moved" from one building to another, to borrow examples from an interview with an HEW administrator149 ; weighing people with disabilities inside a doctor's office, on a scale designed for humans, rather than on an industrial scale in the basement, to borrow an example from the life of DLRC trainer Ann Cupolo. 150 Such changes mattered to the people who requested them. They occurred, trainee Clarinda Valentine recalls, because formerly closed minds "open[ed]" "to new possibilities." 151 And in some instances, the Section 504 trainings catalyzed the openings.

Legacy II: Attitudes and Worldviews

In their qualitative study of Americans with disabilities after the enactment of the ADA, sociologists David Engel and Frank Munger conclude that new legal rights do not necessarily change the legal consciousness of ostensible rights holders, nor do such rights necessarily animate their sense of identity. 152 For some of the disabled trainees that I interviewed, that thesis holds. In the words of an Idaho trainee with cerebral palsy who was in her twenties at the time of her training, "life changing it was not." This trainee remained active around disability issues, some years more robustly than others, but attributed no particular significance to Section 504 or the training she received (and, indeed, seems to have found the CIL approach too dogmatic for her tastes). 153

For other trainees, however, Section 504—or rather, the trainings' interpretation of Section 504—had a noticeable effect. Interviewed twenty years after her training (in Oakland), Johnnie Lacy had this to say, when asked how she felt in the immediate aftermath: "Well, I felt fired up with a new attitude. . . . I left with that sense of righteous indignation that, How dare people look at me in a way that made me feel as though I was less than they as a result of my . . . disability." At that time, Lacy recalled, she had already "mastered that righteous indignation of a black person [and] a poor person," but when it came to her disability, this feeling was new. 154 The low-vision New Mexico trainee that I interviewed also described her training as inspiring—so much so that she moved to Oakland (closer to CIL) and began contemplating a career in law. She associates the training with becoming more assertive and confident. 155

Non-disabled staff members had similar recollections—of seeing people "come politically alive" before their eyes, as wheelchair technician Charles Grimes put it. "It was a reenactment of the kind of consciousness building that happened in the 504 demonstration in '77," he recalled, when interviewed years later, "over and over and over again, for almost every community we went to." 156 Lynette Taylor, who attended some trainings as an interpreter for Deaf trainers and trainees, agreed, while underscoring the more painful aspects of the transformation. In her experience, the trainings prompted people to recall times when they had been isolated, confined, and misdiagnosed, and encouraged them to "reframe" these incidents. Incidents and relationships that they had previously considered acceptable or even benign suddenly had a different cast. "I think with the realization that you have rights, all of a sudden what hits you is all the ways in which you haven't," Taylor reflected, "And so there's a profound sadness about that." 157

Taylor later felt some of that sadness in her own life, as she fought for the rights of her Deaf mother. Her mother was in a nursing home, diagnosed with cancer, and had no ability to communicate with her caretakers. ("My mother thinks—You told her she had leukemia. She thinks she has anemia. So no, it's not working, guys.") Using her knowledge of Section 504, Taylor convinced the facility to provide her mother an interpreter. (Prior to Section 504, a family member or privately-hired interpreter would have been the norm.) When the facility later took away the interpreter, citing cost, Taylor went through the motions again. And again. Taylor's mother died in that nursing home, where, to the end, she was unable to give or receive basic information about her needs. 158

Taylor's story showcases how the trainings could reveal injustices, hitherto tolerated or unacknowledged. In some trainees, the trainings also seemed to inspire a sense that injustices were redressable and that they could do something to alter their place in the world. "I think that for the most part," Taylor recalled, "the audiences were recognizing themselves in someone else or the potential to be something other than they thought they could be. . . . You could feel that in the room." The "empowerment" message was "a game changer in our community," agreed Kathy Martinez, who attended a training as a young adult, became a trainer herself, and eventually became an assistant secretary in the U.S. Department of Labor. The trainings took the sensibility of a "little elite group" in Berkeley and spread it nationwide. 159

From her vantage point at DREDF, Mary Lou Breslin also observed the longer-term "transformative" potential of the trainings. "Years later I would run into people on the metro in D.C. or New York, and I wouldn't remember them from Adam and they would say that I attended your training," Breslin marveled in 2018. 160 (Lawyer Frank Laski, who helped organize PILCOP's Section 504 trainings, has similar recollections: "for years and years afterwards, I would go places and people would say, you know, I was there for the training and I remember . . . ." 161 ) "I think for some people it was the first opening of the door," Breslin reflected. 162 Specifically, Breslin connected the trainings with people's willingness to frame disability-related problems as matters of civil rights and, moreover, to see disability in a structural or social way rather than as an individual deficit. The problem became "the inaccessible city hall, not that I can't walk up the steps." 163 That framing would not have been intuitive, Breslin remarked, "if we hadn't been out there spreading this gospel," including through the Section 504 trainings. 164

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"When those who have been considered 'different' become the source of information about a critical but previously suppressed perspective on the legal issues affecting them," legal theorist Martha Minow has observed, it becomes possible to question "the social and institutional patterns that ignore this perspective." The status quo loses its "natural and inevitable" appearance, to reveal instead a set of choices. Choices can be questioned. Choices "can be remade." 165

The Section 504 trainings seem to have invited such remakings. Did they succeed? When trainees took their knowledge into their communities and articulated their needs, did the people they approached recognize and question their own choices? Did they revise "social and institutional patterns"? Or did they simply make one-off "exceptions" for individuals who presented as particularly deserving or innocuous? 166 The limitations of my sources counsel against strong conclusions, but I hope this article inspires others to search out answers. So, too, must we interrogate the re-framing that Breslin and others describe. To the extent that disabled people embraced that new frame, what kinds of possibilities and futures became visible? Were other possibilities and futures obscured? These intangible legacies of Section 504 are as important as any more measurable consequence.

As we await firmer answers, what this article can conclude is that the Section 504 trainings are an artifact of a vital moment in U.S. disability history, one that fundamentally shaped everything that followed. It was a moment when rights were still the "coin of the realm," 167 a way for government officials to both communicate value and bargain for the kind of behavior they wished to see. Likewise, it was a time when inviting citizens to help enforce their own civil rights seemed like a progressive, democratic development (if also a way of keeping federal enforcement bureaucracy relatively lean). 168 Throughout society, meanwhile, traditional boundaries of exclusion seemed to be eroding. In this political and institutional context, the people who funded, designed, and administered the Section 504 trainings believed they were making great strides. They understood the forces arrayed against their vision, but, inspired by other movements for equality, they imagined their work could lead to a more inclusive society.

With the distance of time, it is also clear that this approach was not adequate to the task (even if it had other underappreciated benefits). During and after the trainings, high-profile court cases illuminated Section 504's limitations: its protection not of every disabled person, but only those "otherwise qualified" for the relevant benefit or program; its concession that not all accommodations were "reasonable"; its acknowledgment that even reasonable accommodations might impose too much of a "hardship" on alleged discriminators to be legally required. Drawing on Section 504's post-enactment interpretations, policymakers built these same limitations into the ADA. 169 What is left is a legal framework that aspires for inclusion, speaks in the alluring register of rights, and has undoubtedly done good in the world, but that has nonetheless proven compatible with inaccessible public transit systems, persistent underemployment, and the funneling of people with disabilities into dangerous congregate care settings—to reference just a few indices of exclusion and subordination. The existing legal framework also continues to rely on disabled people's labor to enforce the law, in a manner that might be called participatory but might also be called exploitative. Although various state and federal agencies have responsibility for enforcing disability civil rights laws, it is often disabled people themselves who identify problems, propose solutions, and seek to hold rights violators to account—generally without government subsidies or support. 170 This is a form of administrative labor, as law professor Elizabeth Emens has argued, albeit one that is undervalued and underrecognized. 171 Amidst narratives of abusive litigation, it also exposes disabled people to dangerous accusations of greed, selfishness, and fraud. 172

Four decades after the end of the Section 504 trainings, disability civil rights laws continue to offer opportunities for individuals to "change the world . . . to what they believe it should be." These laws helped trainee Denise Sherer Jacobson go from being a "prisoner in [her] own house," unable to get a job and afraid of institutionalization, to a nationally known author. 173 They helped trainee Clarinda Valentine adopt and raise two children, defying stereotypes about the parental fitness of wheelchair users. 174 Future possibilities abound. So, too, however, have these laws perpetuated the world as "it is." Our histories must reflect both realities.