In what circumstances have plaintiffs failed to establish that they were denied section 504 disability benefits solely by reason of their alleged disabilities?

In addition, plaintiffs did not establish a further requirement of section 504's third element, which is that the denial of benefits be "solely by reason" of plaintiffs' alleged disabilities. 29 U.S.C. 794(a). Plaintiffs at most demonstrated that they were subjected to inadequate national policies that they claimed reflected deliberate indifference to COVID-19; they did not show they were treated differently from other detainees "solely by reason" of their disabilities. See K.M. ex rel. Bright v. Tustin Unified Sch. Dist., 725 F.3d 1088, 1099 (9th Cir. 2013).