Central Pillar

The Anatomy of an Investigation: How We Document Civil Rights Violations

A complete description of the investigation protocol used in every published report. This page is the office's most-edited document. For the long-form, phase-by-phase walkthrough with worked examples and citations, see The Anatomy of an Investigation.

1. Protocol by vertical

ADA Title III. Geographic-nexus declaration; contemporaneous photograph set with embedded EXIF metadata; dimensional measurements against the 2010 ADA Standards (28 C.F.R. pt. 36, app. B); disability-specific barrier impact narrative; concrete intent-to-return record.

ADA Title II. California Public Records Act request set (see the CPRA Template Library); GIS overlay of barriers within the public right-of-way; municipal self-evaluation and transition-plan audit against DOJ standards; citizen-complaint record consistent with the Betancourt-Colón template.

Prop 65 / BPS. Sample acquisition under NIST IR 8387-aligned chain of custody; sealed evidence transfer to independent laboratory; dermal-transfer exposure assessment citing Biedermann et al. (2010); pre-suit memorandum prepared under Cal. Health & Safety Code § 25249.5.

2. Evidence preservation

Every artifact entered into an investigation file is captured under three standards: contemporaneous timestamp, geolocation, and unbroken chain of custody. Photographs are hashed at the moment of capture; metadata is preserved without re-encoding; transfer to counsel is logged.

Capture devices, hash function (SHA-256), transfer-log format, and retention schedule are documented in the per-file evidence log published with each investigation report.

3. Deposition-survival checklist

The six questions defense counsel asks an ADA plaintiff or tester — and the documented answers produced by this office's protocol. This list is published by design: a defensible investigation has nothing to hide from a deposition.

The full six-question list with citation map is published in The Anatomy of an Investigation (Phase 6: Legal Mapping).

4. Anti-surrogate policy

No investigation file produced by this office is generated by a surrogate tester operating under another named plaintiff's identity. Every named plaintiff personally encountered the barriers documented in the file attributed to him or her. Every field investigator is personally identified in the file. This is a structural commitment, not a representation.

See also: What We Do Not Do.

5. Litigation-exhibit screen

Before any investigation report is published, the file is reviewed against an internal editorial standard: would each photograph, measurement, and narrative statement be admissible and survive cross-examination as a trial exhibit? Items that fail this screen are redacted or removed before publication.

6. Peer reviewer credentials

Each vertical has a named peer reviewer whose credentials are published with the methodology. Prop 65 / BPS investigations are reviewed by a named scientific advisor. Title III investigations are reviewed by an experienced CASp inspector. Title II investigations are reviewed by a named municipal accessibility specialist.

Each peer reviewer is named in the report file he or she has reviewed; the reviewer roster is therefore published per-file rather than as a separate roster page.