Sierra v. City of Hallandale Beach, No. 18-10740 (11th Cir. 2018)
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The Twenty-First Century Communications and Video Accessibility Act of 2010 does not create an administrative exhaustion requirement that must be satisfied as a prerequisite to bringing certain claims under section 505 of the Rehabilitation Act of 1973 and Title II of the Americans with Disabilities Act of 1990 (ADA). If exhaustion is not required, abstention is not nonetheless warranted under the primary-jurisdiction doctrine.
Plaintiff filed suit against the city alleging that four of the city's webpages did not provide closed captioning in violation of the Rehabilitation Act and the ADA. The court vacated the district court's grant of the city's motion to dismiss based on lack of subject matter jurisdiction, holding that the district court had no reason to invoke the primary jurisdiction doctrine.
The court issued a subsequent related opinion or order on May 6, 2021.
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