Vertical 02

ADA Title II — Municipal Accessibility

Title II governs services, programs, and activities of state and local government. Municipal investigations in this office are records-driven first and field-driven second — a defensible Title II case rests on the public record the entity itself maintains under 28 C.F.R. pt. 35.

1. Scope of the vertical

The vertical concentrates on three Title II program areas with the most documentable evidence trail: (i) public rights-of-way (curb ramps, sidewalks, pedestrian signals); (ii) public facilities (city halls, parks, libraries, polling places); and (iii) digital services subject to the DOJ Title II web rule (28 C.F.R. § 35.200, eff. April 24, 2024).

2. CPRA workflow

Every municipal investigation begins with a structured set of California Public Records Act requests. The full set is published at /resources/cpra-templates — 17 records every Title II investigator should obtain before opening field work.

Production timelines are tracked under Cal. Gov't Code § 7922.535. Where the entity invokes an extension, the office's protocol requires written follow-up at the close of each extension window.

3. GIS barrier mapping

Curb-ramp and sidewalk audits are overlaid against the entity's own GIS layer (where produced under CPRA) using open-source GIS tooling. Field- measured barriers are added to a corresponding investigator layer, hashed and time-stamped, for litigation-exhibit production.

4. Self-evaluation & transition-plan audit

The entity's most recent self-evaluation (28 C.F.R. § 35.105) and transition plan (§ 35.150(d)) are audited against DOJ standards: scope, schedule, milestones, official responsible, and update cadence. Gaps between the published plan and field-observed conditions are catalogued.

5. Betancourt-Colón template summary

The office's Title II municipal workflow is modeled on the structured public-records-plus-citizen-complaint approach developed in the Betancourt-Colón template. The template's contribution is a rigorous evidence trail showing both that the public entity was on notice of the barriers and that its transition plan did not schedule remediation within a reasonable time.

6. Published investigations

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