ADA Failure to Accommodate Complaint

Generates a litigation-ready complaint under ADA Title I (employment) or Title III (public accommodations) for federal or state court. Determines applicable title from intake facts, structures numbered allegations to satisfy Twombly/Iqbal plausibility, and produces a complete pleading with causes of action and prayer for relief.

Intake Checklist

Gather before drafting:

• Plaintiff name, state of residence
• Disability: diagnosis, functional limitations, treating provider
• Accommodation request: date, form (oral/written), recipient, specific accommodation, medical documentation submitted
• Defendant response: denial letter, non-response timeline, or interactive process failure evidence
• Title I only: job description, hire date, performance reviews, adverse action date/reason
• Title I only: EEOC charge number, filing date, Right to Sue date, receipt date
• Damages: pay stubs, W-2s, benefits records, therapy/treatment records

Complaint Structure

Draft the following sections in order: