Americans with Disabilities Act (ADA) Complaint Template

United States District Court for the [District] of [State]

[Plaintiff Name], an individual with a disability,
Plaintiff,

v.
[Defendant Name], [business/entity],
Defendant.

Case No. [To be assigned]

COMPLAINT

Plaintiff alleges:

I. Jurisdiction and Venue

1. This action arises under Title III of the Americans with Disabilities Act (42 U.S.C. § 12181 et seq.) and related state laws.
2. Jurisdiction is proper pursuant to 28 U.S.C. §§ 1331, 1343, and 1367.
3. Venue is proper in this District pursuant to 28 U.S.C. § 1391 because the property or acts complained of occurred within this District.

II. Parties

4. Plaintiff [Name] is an individual with a disability within the meaning of the ADA who resides in [City, State].
5. Defendant [Name] owns/operates [property/business] located at [Address], which is a place of public accommodation.

III. Factual Allegations

6. Plaintiff visited [property] on [Date(s)] and encountered barriers that denied full and equal access, including [describe architectural barriers, policies, lack of auxiliary aids].
7. Barriers identified include, but are not limited to:
   - [E.g., inaccessible parking spaces]
   - [Improper slopes or ramps]
   - [Inaccessible restrooms]
   - [Failure to provide effective communication]
8. Plaintiff intends to return to the property but is deterred by ongoing barriers.
9. Removal of the barriers is readily achievable or alternative methods of providing access are available.
10. Defendant has failed to make reasonable modifications in policies, practices, or procedures when necessary to accommodate individuals with disabilities.

IV. Causes of Action

Count I – Violation of Title III of the ADA

11. Plaintiff realleges paragraphs 1-10.
12. Defendant has discriminated against Plaintiff by failing to remove architectural barriers and provide equal access as required by 42 U.S.C. § 12182(b)(2)(A).

Count II – State Accessibility Law (if applicable)

13. Defendant’s conduct also violates [state statute/civil rights law].

V. Injunctive Relief

14. Plaintiff seeks an injunction requiring Defendant to:
    - Remove identified architectural barriers or provide compliant alternatives.
    - Implement policies ensuring ongoing compliance with accessibility standards.
    - Provide training to staff regarding ADA requirements.

VI. Attorneys’ Fees and Costs

15. Plaintiff is entitled to reasonable attorneys’ fees, litigation expenses, and costs under 42 U.S.C. § 12205 and applicable state law.

VII. Prayer for Relief

WHEREFORE, Plaintiff requests judgment against Defendant for:
- Declaratory relief that Defendant violated the ADA;
- Injunctive relief compelling compliance;
- Reasonable attorneys’ fees, costs, and expenses; and
- Any other relief the Court deems just and proper.

VIII. Jury Demand

16. Plaintiff requests a jury trial on all triable issues (if applicable under state law claims).

Respectfully submitted,

[Law Firm Name]

By: ________
[Attorney Name] (Bar No. [Number])
[Address]
[Phone]
[Email]

Date: [Date]