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Can an ADA website accessibility claim be mooted?

April 21, 2023 By Richard Hunt in Accessibility Litigation Trends, ADA - drive-by litigation, ADA - serial litigation, ADA Internet Web, ADA Mootness Tags: ADA defense, Diaz v Kroger, mootness, Tavarez v Extract Labs, website accessibility

painting of the battle of bunker hillIn ADA website litigation failure  can teach us as much as success, and the plaintiff’s failure in Tavarez v. Extract Labs, Inc., 2023 WL 2712537, at *2 (S.D.N.Y. Mar. 30, 2023) is no exception.¹ Before getting into the details, here’s a primer on the doctrine of “mootness.”

Article III of the Constitution gives federal courts jurisdiction over “cases and controversies.” Just what this means has been the subject of many cases in the last two hundred years, but one thing it certainly means in the context of an accessibility lawsuit under Title III of the ADA is that if there is no accessibility problem to fix there is no case or controversy and the lawsuit is “moot.”  This kind of mootness is almost unique to ADA Title III lawsuits and comes from the fact that that the only thing a federal court can do in an accessibility lawsuit under Title III is order that the problem be fixed. I call this the “if it ain’t broke you can’t fix it” defense.

Mootness is a great defense because it concerns the power of the court to hear the case and it can therefore be raised at any time, even while the case is on appeal. If the case is moot the only thing the court can do is dismiss the case. And even if the lawsuit was the reason the accessibility problem got fixed the plaintiff and the plaintiff’s lawyers get nothing. This is obviously a very gratifying result for those of us who don’t think serial litigation does anything but make lawyers rich.

Mootness is a great defense, but it is not an easy defense to establish. As the court observes in Extract Labs, a case can be found to be moot only if the defendant meets the:

‘formidable burden’ of demonstrating that it is ‘absolutely clear the alleged wrongful behavior could not reasonably be expected to recur.’

This is not easy with website cases because websites are complicated and dynamic. Because they are complicated it can be hard to show that there is literally nothing wrong that interferes with meaningful access, and because they are dynamic it is hard to prove something won’t go wrong in the future. Nonetheless, mootness has been successful as a defense. Diaz v. Kroger was the first case to find for a defendant on mootness and shows just how hard it can be.² The defendant in that case succeeded because it proved that its website conformed to WCAG 2.0 AA, the best available standard at the time, and that none of the barriers to access specifically alleged in the Complaint existed. It dealt with the possibility of future inaccessibility by proving that even before it was sued it had a policy of keeping the website in conformance to WCAG 2.0 AA, a policy that the plaintiff had no proof would not work.

For a trial lawyer it isn’t hard to see how a plaintiff can avoid a mootness defense. You need one of two things. First, you need to find a defect in the website that wasn’t fixed. The Diaz decision cites several cases where this was the problem. As an alternative, you can provide some evidence that the policy of keeping the website accessible is not trustworthy. Courts are suspicious of policies that are enacted only after a lawsuit is filed. In addition, if the policy has already failed that is pretty good evidence it doesn’t work.

At first glance it would seem the plaintiff in Extract Labs did what he needed to do. The defendant had a declaration that was modeled on the successful declaration in Diaz v Kroger, but unlike the plaintiff in Diaz v Kroger, the plaintiff in Extract Labs had an expert with a declaration that said there were problems with accessibility. Despite this, the defendant won and the case was dismissed. Why?

The problem was not in what the plaintiff’s expert said, it was that he didn’t say it in a way the court believed. Courts are not technical experts in website accessibility so they rely on experts who tell them what the expert found. This comes in the form of an opinion that summarizes a lot of facts – something like “in my expert opinion the website is not accessible.” Facts are also needed as examples to support the opinion, and the rules about balancing opinions and supporting facts are complicated, but one thing about this process is not. Only experts get to give this kind of opinion and so they have to prove they really are experts. That requires some facts as well, like what training they had, or what experience they bring to the table.³

In this case the plaintiff’s expert and the plaintiff’s lawyers appear to have just messed up. The expert did not include his resume, so there wasn’t specific evidence he was an expert. He also left out his “audit report” that would have provided fact to back up his opinion. Finally, and perhaps worst, he failed to fix these problems even though he had eight months to do so. The net result:

Evidentiary deficiencies with Plaintiff’s submission of Moody’s declarations compel the Court to grant Defendant’s request to strike the Moody statements as unreliable and lacking foundation.

With no competent evidence of website problems from the plaintiff the defendant was bound to win.(5)

The takeaway for businesses concerned with website accessibility is simple: Hope you get sued by a plaintiff whose lawyers are not on the ball. But even if the opposition isn’t up to snuff you need to give yourself the best chance to establish mootness by:

  • Adopting and  implementing a policy to have an accessible website now, before you’ve been sued.  That will fit you into the winning model found in Diaz v Kroger.
  • If you get sued, make sure you both meet WCAG 2.1 and take care of every specific problem listed in the Complaint. Remember that because WCAG 2.1 has subjective elements just saying you meet WCAG 2.1 does not mean you will have fixed everything in the Complaint. You have to do both.

I’ll add my opinion of one more strategic decision. Don’t fire until you see the whites of their eyes.(4) A defendant can win a case at three times; at the beginning with a Motion to Dismiss, in the middle with a Motion for Summary Judgment, and at the end by proving the truth at trial. Winning based on the truth gets easier at each step, though at the cost of spending more money to get there. I think legal fees for a mootness defense are best spent at the Motion for Summary Judgment stage where the odds are better. This defendant won on a Motion to Dismiss that was treated like a Motion for Summary Judgment, but only because the plaintiff’s lawyers made a mistake. The odds are better later in the case.

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¹ My friend Bill Goren (https://www.understandingtheada.com/) called this case to my attention, along with the blog post from Jeff Singleton at Converge Accessibility (https://convergeaccessibility.com/2023/04/19/can-using-an-overlay-win-a-lawsuit/)

² See my blog: Accessibility moots a website accessibility claim – a surprising decision that shouldn’t surprise anyone. As for the Battle of Bunker’s Hill, the subject of the painting at the left, just keep reading.

³ This is all based on Federal Rule of Evidence 702 and 703 and some important cases from the Supreme Court saying what they mean.

(4) See https://www.encyclopedia.com/history/dictionaries-thesauruses-pictures-and-press-releases/dont-fire-until-you-see-white-their-eyes if you are interested in the history of this saying.

(5) it is worth emphasizing that this opinion doesn’t tell us much about what it means to have an accessible website because there was, in effect, only one side of the story being told.


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Like death and taxes – an ADA serial filer roundup.

April 15, 2023 By Richard Hunt in ADA, ADA - drive-by litigation Tags: "drive-by" ADA lawsuits, ADA defense, ADA serial litigants, Duncan Strickland, Sapp & Sturgill, Sarah Murray, Scott Johnson

image of IRS Form 1040Like death and taxes, serial ADA litigants seem inescapable, but if the lawsuits remain the same the players change from time to time. It’s worth knowing who’s who when you or your client gets sued.

First, in the just rewards category, Scott Johnson, whose name appears dozens of times in my blog posts, and thousands of time as the plaintiff in ADA lawsuits has been sentenced to 18 months of home detention and a healthy fine for tax evasions. You can read about it here: Carmichael attorney known for suing under ADA sentenced for filing false tax returns. I recently wrote about the Ninth Circuit’s unwillingness to treat the truth as something important in ADA serial filer cases.¹ Of course just because the Court found he lied on his taxes doesn’t mean Johnson was being untruthful when he swore, thousands of times, that he intended to go back and patronize businesses he had never patronized for any reason other than filing ADA lawsuits, right?

Now on to Florida. Like others who follow ADA developments I have known from my research that Florida is a hotbed of serial filer activity. I only recently had to deal with a Florida serial filer and really got a first-hand view of the extent of the industry. Douglas Longhini, for example, appears to have filed hundreds of lawsuits in the last several years, which isn’t up to Deborah Laufer or Scott Johnson rates, but is more than enough to cast doubt on his claim that he is doing anything but trolling for lawsuits. Longhini is far from alone in this enterprise; other names with multiple lawsuits include Renzo Barberi, Howard Caplan and Ryan Turizo. There is also an entity serial filer, Florida Fair Housing Alliance, Inc. that was incorporated by Turizo and represented by his attorneys. It was incorporated in 2020, filed a number of lawsuits based on “testing” apartment complexes by making pretextual phone calls, and then dissolved in January of this year. It dismissed its last case on the day of the scheduled hearing on the defendant’s motion to dismiss. The dismissal was without prejudice; an almost sure sign that FFFA surrendered rather than face scrutiny by the Court. I also can’t say I know of any legitimate non-profit disability advocacy groups that exist only long enough to file lawsuits and then dissolve.

The other news from Florida is that Sarah Murray of Murray & Associates is continuing to send demand letters claiming she represents Pursuit of Respect. The last time I checked into Pursuit of Respect and Ms. Murray neither ever appeared to have filed an ADA lawsuit and checking today showed the same thing. Pursuit of Respect, Inc. seems to have a law office as its address, and a minimalist website that hasn’t been updated since I first looked at it in 2020. Ms. Murray’s demand letter continues to invoke the Fair Housing Act, which has no requirement for website accessibility, so I assume she is just looking for suckers who will pay her because she’s a lawyer and sounds official.

Headed north to New York, lawyers and their clients continue to exploit the fact that most district judges in the Second Circuit continue to believe the ADA covers stand-alone websites and are reluctant to grant motions to dismiss. Barclay Damon recently blogged about a new crop of plaintiffs represented by Stein Saks: ADA Accessibility Lawsuits: New “Tester” Plaintiffs—Bryan Velazquez, Daniel Rodriguez, Marina Iskhakova, Elbert Dawkins, Marta Hanyzkiewicz, and Warren Zinnamon—Targeting Businesses in Recent Flurry of Federal Lawsuits. Stein Saks is only one of several firms that continue to file these lawsuits. From my experience lawsuits filed in federal court in New York are generally filed by firms with a least some ability to prosecute the suit. They represent a real threat but I am told that four figure settlements are available.

Speaking of New York, I recently heard a name I had not run across for several years, CityVision Services. The last time I blogged about this group was in 2017, when they were operating in Texas filing discrimination complaints against apartments that supposedly discriminated against individuals with service dogs.² Michael Hutter, an attorney in New York, told me about a recent decision against CityVision in a housing discrimination complaint filed against one of this clients. Besides a victory on the underlying discrimination complaint his client beat a retaliation claim. You can read the decision here: Court Decision. I had not been keeping track of CityVision since it more or less departed Texas, but based on ProPublica’s look at it it seems to be a shadow of its former self and reported revenues have tumbled since 2016. Propublica Article.³

The Western District of Pennsylvania is, as it has been since 2015, a very hospitable place for serial ADA litigation. About 250 ADA lawsuits were filed in 2022 with the usual list of serial plaintiffs: Charlap, Douglass, Murphy, Jahoda, Kolesar, McCann, McMoreland, Niles and few others with fewer lawsuits. As long as judges in the Western District are receptive to these cases and willing to overlook the very obvious problems of standing for professional plaintiffs the filings will continue. As with New York, the lawyers involved are capable of prosecuting the cases and often demand five figure settlements.

Here in Texas, the roster serial filers haven’t changed much in the last few years. Sapp & Sturgill PLLC and Duncan Strickland continue to file lawsuits in the Western and Northern Districts for plaintiffs who, amazingly enough, always live within 30 miles of the business they sue, no matter where it is. It isn’t clear where the plaintiff is going, but they always pass the business frequently although, boilerplate filings being the rule, the list of things they might have been looking to buy is the same for a sports bar as a pawn shop. In North Texas Douglas Shapiro files lawsuits at a steady pace and recently Ku & Mussman seem to have filed a few as well.

I was surprised to hear the Bruce Tharpe, who I last mentioned in 2021 (4) has been very active  in the Southern District of Texas. He was notable in the Northern District for targeting Asian businesses located in a relatively small geographic area. I haven’t analyzed his filing pattern in the Southern District except to note that for his current plaintiff, Randy William Brast, he files on a monthly basis, with 8 to 10 lawsuits filed on the same day each month. I found it interesting that one of his recent complaints, filed against La Pupusa Loca (Case No. 4:23-cv-01340 in the Southern District of Texas) includes photos of the defendant restaurant intended to show it has no accessible parking. They also show pretty clearly that it was closed because the parking lot is completely empty. And they don’t show the accessible parking further along the building. Trying to eat at a restaurant that isn’t open is going to create problems that have nothing to do with accessibility.

This sort of thing intrigues me, so I checked another case filed the same day, Brast v Columbian Cuisine, Case No. 4:23-cv-1339 (SD Tex). Pictures again, this time with the parking lot empty except for a single truck parked in front of the restaurant. Google Earth helpfully showed me that an accessible parking spot is two stores away, in front of Sherwin Williams. This isn’t surprising because major retailers are usually pretty careful about ADA compliance. A shopping like the one where Columbian Cuisine is located does not need an accessible parking space in front of every storefront – only the correct number in various locations. Mr. Tharpe, having filed hundreds of ADA lawsuits, presumably knows this and presumably doesn’t care.

Next natural stop on a tour of serial filers would be California, but cases from California appear so frequently in this blog that I’m going to skip it. In the meantime, if you have a favorite serial filer that I’ve overlooked, or suspect you’ve gotten a lawsuit or demand letter from one, please let me know.

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¹ When it comes to ADA tester standing in the Ninth Circuit, the truth no longer matters.

² Good news for those attacked by CityVision’s FHA complaints

³ It is important to note that “CityVision” and “City Vision” are names used by several completely legitimate businesses and non-profits. CityVision Services, Inc. can be distinguished by the fact that it does not appear to have a website and is associated with Gary Lacey.

(4) FHA and ADA Odds and Ends. Tharpe has an interesting personal story. You should Google him.


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ADA serial litigation – will the Supreme Court cut off the head of this snake?

March 31, 2023 By Richard Hunt in Accessibility Litigation Trends, ADA, ADA - Hotels, ADA - serial litigation Tags: ADA defense, Havens Realty, Laufer v Acheson Hotels, serial litigation, tester standing

ouroboros - snake devouring itselfOuroboros – the snake devouring its own tail is, according to Encyclopedia Brittanica, an ancient symbol of the endless cycle of death and rebirth. It’s a little like serial litigation under the ADA, where the same old issues and plaintiffs have been appearing and re-appearing for at least a decade. Now, however, it looks like there may be a real breakthrough (or setback, depending on where you stand).

On March 27 the Supreme Court granted certiorari in Acheson Hotels LLC v. Laufer, one of several recent appellate decisions addressing whether one of the most prolific ADA serial filers of all time, Deborah Laufer, has standing to sue hotels she never intends to visit because their websites lack accessibility information. You can read the background to this unfolding story in many places, including this blog and others.¹ A decision that Ms. Laufer does not have standing could – depending on how it is written, finally cut the head off this particular snake and end the cycle of serial ADA litigation.

By way of background, the Supreme  Court reminded us in the Transunion  case that there are two steps in a question about standing to sue under a federal statute. Step one is whether Congress created an injury that the plaintiff can sue for. This is a question of statutory interpretation. Step two is whether that injury is sufficient to satisfy the requirements in Article III of the Constitution. Just because a statute creates an injury doesn’t mean it is the kind of injury sufficient for the Constitution. The constitutional standing issue was the exciting part of Transunion and justifiably got all the attention.

The petition for certiorari in Acheson Hotels argues primarily that Laufer lacks constitutional standing, but although it isn’t as sexy I think the Supreme Court can avoid the constitutional standing issue because Laufer did not suffer a statutory injury. “Tester standing” cases holding in favor of ADA serial litigants like Laufer rely on the Supreme Court’s decision in Havens Realty Corp. v. Coleman for the notion that testers can suffer a statutory injury, so it seems Haven would have to be overruled to decide against Laufer. That idea mis-reads Havens the tester standing cases uniformly ignore the most important phrase in that decision and therefore reach the wrong conclusion about what Congress intended when it passed the ADA.

Havens is often characterized as a case about tester standing, but that is a misleading generalization. In Havens black and white testers tried to get information about apartments under the pretense of wanting to rent. The white tester was told the truth – apartments are available – but the black tester was told a lie – apartments are not available. They sued claiming violations of two sections in the Fair Housing Act, §3604(a), which prohibits a discriminatory refusal to rent, and §3604(d), which prohibits discriminatory lying about the availability of an apartment. The Supreme Court found that the black tester could not sue under §3604(a) because it explicitly requires a bona fide intention to rent, which the black tester did not have. That brought it to the standing question: had the black tester suffered an injury when he was lied to about an apartment he never intended to rent anyway.

Since Supreme Court decisions are precisely written, it is worth looking at what the Court said when it discussed this issue:

The black individual respondent (Coleman) has standing to sue in her capacity as a “tester.” Section 804(d) establishes an enforceable right of “any person” to truthful information concerning the availability of housing. A tester who has been the object of a misrepresentation made unlawful under § 804(d) has suffered injury in precisely the form the statute was intended to guard against, and therefore has standing to maintain a damages claim under the Act. That the tester may have approached the real estate agent fully expecting that he would receive false information, and without any intention of buying or renting a home, does not negate the fact of injury within the meaning of §804(d). If, as alleged, Coleman was told that apartments were not available while white testers were informed that apartments were available, she has suffered “specific injury” from petitioners’ challenged acts, and the Art. III requirement of injury in fact is satisfied.

I have highlighted the critical language, “injury in precisely the form the statute was intended to guard against.” If you want to know whether a tester has suffered an injury created by statute you have to ask what injury the statute was intended to prevent. Whether they call themselves a tester is irrelevant because no matter what their motivation, they can only sue if they have suffered an injury in precisely the form the statute was intended to guard against. If they have not the lack of constitutional standing is irrelevant. You never get to that question.

So just what injury was Title III of the ADA intended to guard against? That question is answered in 42 U.S.C. §12182(a), the general prohibition on disability discrimination. Title III is intended to guard against discrimination:

on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place of public accommodation

Every following subsection and regulation merely elaborates on how discrimination might occur; they do not enlarge the harm Congress intended to prevent, which was discrimination on the basis of disability in the full and equal enjoyment of goods, facilities and so on.

Cases looking a Havens often conclude that an ADA tester can suffer an injury without a bona fide intention to use goods and services because the black tester in Havens had no bona fide intention to rent. That claim ignores the Supreme Court’s careful observation that §3604(d) is not about renting, but about obtaining truthful information. The harm the statute was intended to protect against was getting false information because of race; that harm did not depend on how the information was or was not going to be used.

Now let’s look at Ms. Laufer. The regulations interpreting the statute require that hotel websites provide information about accessibility. Is this requirement that information be provided analogous to the requirement of truthful information in §3604(d)? No. Section 3604(d) does not prohibit lying in general about the availability of an apartment. It only prohibits lying with a discriminatory motive. If the defendant in Havens lied to everyone regardless of race there would have been no violation of §3604(d). There was a violation only because the white tester was told the truth and the black tester was lied to. The hotel website regulations require the same information be provided to everyone, whether or not they are disabled. If a website lacks the information it is not discriminating by providing non-disabled people different information than disabled people; it treats everyone equally. The black tester in Havens suffered an injury his white counterpart did not. Ms. Laufer suffered exactly the same injury a non-disabled visitor to the hotel website would suffer.

Of course in theory the information might have been more meaningful to Ms. Laufer than to a non-disabled person² who did not need the information. But since the regulation itself does not distinguish among users we have to turn back to the Supreme Court’s inquiry – what is “injury in precisely the form the statute was intended to guard against?” That injury is denial of equal access to goods, facilities, services and so on because of a disability. Someone who does not intend to visit a hotel cannot suffer that injury no matter what they find or do not find on the hotel website.

Laufer advocates will say that this is too narrow a definition of ADA injury; that access to the information itself is protected by Title III and so denying her the information is an injury. The problem is that §12182(a) only prohibits “discrimination on the basis of disability” in access to goods, services, etc. The absence of information on a hotel website is not discrimination on the basis of disability because no one, regardless of disability, has access to information that simply isn’t there.

The last thin reed upon which a pro-Laufer argument can be made is that although the lack of information is not discriminatory in the sense that some get the truth and some don’t, it is discriminatory because it offends the dignity of a disabled person in a way that it doesn’t offend the dignity of a non-disabled person.  The first flaw in this argument is the assumption that those with disabilities are necessarily more sensitive to implicit slights against them than non-disabled persons might be. Someone with a brother, child or parent who is disabled may well be just as offended by the perceived disrespect in a website that lacks information on accessibility as a person who is themselves disabled. For this very reason it makes no sense to say the ADA was intended to protect the dignity of those with disabilities in a way that is disconnected from their access to goods, services and facilities. Surely, if Congress intended to make an implied assault on the dignity of a disabled person illegal it would have said so, rather than prohibiting discrimination in access to goods and services.

In addition, the notion that Laufer suffered a “dignitary injury” when she could not find accessibility information fails to consider the nature of the dignitary injury suffered by someone who is a victim of discrimination. The black tester in Havens was not merely lied to – he was lied to because of his race. Ms. Laufer, on the other hand, did not fail to get information because of her disability – she failed to get information because it was not there for anyone, disabled or not. The ADA has many aspects of affirmative action based on the idea that equality of access may require special treatment, but the justification is always equality of access. The fundamental rule is that those with and without disabilities must be treated equally, and it is no insult to the dignity of a person with a disability if they get equal treatment.³ Ms. Laufer never suffered an injury the ADA was intended to prevent and therefore lacks statutory standing. She certainly lacks constitutional standing as well, but a careful reading of Havens and the text of the ADA shows that the Court never has to get to the question of constitutional standing because Ms. Laufer was never a victim of the discrimination the ADA is intended to prevent.

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¹ A few places to start:

Stigmatic Injury, how the 11th Circuit got it wrong

Laufer v Looper – the death of tester standing

Laufer v Looper Ch. 2

Laufer Headed to Supreme Court: Tester Standing under Title III

² We’ll assume our non-disabled website visitor is not looking because they have a disabled associate, but has a purely academic interest.

³ Ms. Laufer would not know that her dignity was under assault if she did not know that buried in the Code of Federal Regulations is a requirement for some kinds of accessibility information.  Comparing Ms. Laufer’s situation to victims of intentional discrimination is an insult to those the ADA and other civil rights statutes were meant to protect.


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Learn about the ADA, FHA and Connecticut accessibility laws.

March 22, 2023 By Richard Hunt in ADA, FHA, FHA Training Tags: ADA, CLE, Connecticut Bar Institute, FHA, Real Estate Law

two trumpetsI’ll be presenting a two hour live webinar titled “What Real Estate Lawyers Need to Know About the ADA, FHA, and CT Accessibility Laws”  for the Connecticut Bar Association on April 4, 2023 at noon Eastern Time. If your clients buy, sell or manage shopping centers, commercial properties, multi-family housing,  single family housing developments, or home owners associations you need to understand their obligations under the Americans with Disabilities Act, Fair Housing Act, and Connecticut’s fair housing and public accommodation accessibility laws. Even if you don’t practice in Connecticut you’ll find this presentation helpful because so much of Connecticut law tracks the equivalent federal statutes. Sign up at the link above.


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Hear all about it – Richard discusses ADA website litigation on the ADA Book podcast

February 10, 2023 By Richard Hunt in ADA, ADA - drive-by litigation, ADA - serial litigation, ADA Internet, ADA Internet Web, ADA Web Access Tags: ADA Book, ADA defense, ADA Website Litigation, Kris Rivenburgh

Richard was interviewed this week by Kris Rivenburgh on his ADA Book YouTube channel and podcast, which is now streaming at https://www.youtube.com/watch?v=rMwsgy57kC4 and all your major podcast sources. The interview covers the latest legal developments as well as prospects for future regulation and litigation. Businesses concerned with ADA website compliance might want to check out Kris’s ADA Compliance course at https://adacompliance.net.

 


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Richard M. Hunt


Hunt Huey PLLC
3010 Mountain Ash Court
Garland, Texas 75044
972-675-2236 phone
214-279-6124 fax
rhunt@hunthuey.com

I defend businesses nationwide in ADA and FHA accessibility lawsuits and consult with businesses and other attorneys concerning how to promptly and effectively deal with ADA and FHA demands, minimize litigation risk, and obtain meaningful compliance with the ADA and FHA. For more information about this feel free to email me at rhunt@hunthuey.com or visit our firm web site, hunthuey.com

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