Is there a disparate impact cause of action under the Rehabilitation Act?

^[3] See, e.g., CG v. Pennsylvania Dept. of Educ., 734 F.3d 229, 236 n.13 (3d. Cir. 2013) (assuming the existence of a disparate impact cause of action in denying plaintiffs' meaningful access challenge to Pennsylvania's school funding formula, but did not decide the issue).

^[4] See, e.g., Valencia v. City of Springfield, 883 F.3d 959 (7th Cir. 2018) (stating that disparate impact claims are permissible under the Rehabilitation Act without mentioning the impact of Sandoval).