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Law grad can move forward with suit over bar exam accommodations, appeals court says

By Amanda Robert

May 21, 2026, 9:50 am CDT

The appellate court in Colorado has revived a lawyer’s disability discrimination claim against the state’s attorney regulation office.

In a May 7 opinion, the Colorado Court of Appeals said Michael Ozborn, a University of Denver law graduate, “plainly stated a claim for discrimination” when he filed suit against the Colorado attorney regulation counsel office, an independent office of the Colorado Supreme Court, in June 2024. Ozborn has multiple disabilities and alleged that the office twice denied his request for accommodations on the July 2024 bar exam.

The Colorado attorney regulation counsel office granted Ozborn’s request after he filed the lawsuit, but Ozborn said by then, he was “in a diminished emotional state” and no longer prepared for the bar exam, according to coverage from Colorado Politics. He later took and passed the exam in February 2025.

While a district court judge dismissed Ozborn’s suit for lack of standing, stating that the attorney regulation counsel office eventually gave the plaintiff the necessary accommodations, the appeals court disagreed with that decision.

“When Ozborn filed the original complaint, he alleged that he was entitled to accommodations and had been denied those accommodations in violation of [the Colorado Anti-Discrimination Act],” the court’s opinion said. “Thus, Ozborn alleged an injury in fact to a legally protected interest and had standing at the time the action was commenced.”

The appeals court acknowledged that Ozborn amended his complaint to include claims of retaliation and future discrimination but said that “does not mean we reassess standing as of the date of the later complaint.”

“Moreover, that OARC later granted Ozborn’s request for accommodations does not mean he suffered no injury,” the court added.

The appeals court reversed the dismissal of Ozborn’s discrimination claim but affirmed the district court’s dismissal of his retaliation and future discrimination claims. It remanded the case back to the lower court.

The attorney regulation counsel office did not provide comments to Colorado Politics.

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