What is the test for a claim under section 504(1) of the US Civil Code for discrimination on the basis of handicap?

"[i]t would be a rare case indeed in which a hostile discriminatory purpose or subjective intent to discriminate solely on the basis of handicap could be shown. Discrimination on the basis of handicap usually results from more invidious causative elements and often occurs under the guise of extending a helping hand or a mistaken, restrictive belief as to the limitations of handicapped persons. A claim under 504 would be analyzed more readily under a 'disparate impact' theory where it is claimed that a facially neutral practice has a discriminatory impact on persons within a protected class." Id. (citing Griggs v. Duke Power, 401 U.S. 424, 91 S.Ct. 849, 28 L.Ed.2d 158 (1971)) (emphasis added).