ADA Failure to Accommodate Complaint

Drafts a federal complaint for ADA failure-to-accommodate claims under Title I (employment) or Title III (public accommodations). Structures all required sections to satisfy Twombly/Iqbal plausibility.

Prerequisites

Gather before drafting:

• Client — full legal name, address, state of residence
• Disability — diagnosis, functional limitations, treating provider
• Accommodation request — date, form (oral/written), recipient, exact accommodation sought, supporting medical docs submitted
• Defendant — legal name, business form, principal place of business, employee count (Title I: ≥ 15 for ≥ 20 calendar weeks)
• Adverse action — termination, demotion, denial of access, or constructive discharge with dates and stated reasons
• EEOC record (Title I only) — charge number, filing date, Right to Sue letter with issue date
• Damages — lost wages (start date), lost benefits, out-of-pocket costs, emotional distress treatment records

Complaint Structure

Caption & Header