United States of America v. Camp Bravo - Settlement Agreement

BACKGROUND

1. The parties to this Settlement Agreement are the United States of America and Camp Bravo.

2. This matter is based upon a complaint filed with the United States Department of Justice alleging that Camp Bravo discriminated against an individual with a disability in violation of title III of the Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12181-12189.  Specifically, the Complainant alleged that Camp Bravo refused to admit her daughter because she has epilepsy and requires certain medication be administered to her in emergency situations.

3. The Attorney General is responsible for administering and enforcing title III of the ADA, 42 U.S.C. §§ 12181-12189, and the regulation implementing title III, 28 C.F.R. Part 36.

4. The Complainant is the mother of a child who has epilepsy.  Epilepsy is a physical impairment that substantially limits one or more major life activities, including neurological functions during a seizure.  An episodic impairment, such as epilepsy, is a disability if it substantially limits a major life activity when active.  42 U.S.C. § 12102(4)(D).  Accordingly, the Complainant's daughter has a disability within the meaning of 42 U.S.C. § 12102 and 28 C.F.R. § 36.104.

5. Camp Bravo is a private day camp for children ages 4½ through sixth grade.  The summer camp hosts two four-week sessions on the Campus of Goucher College in Towson, Maryland.  During the winter, Camp Bravo's place of business is located at 2027 Middleborough Road, Baltimore, Maryland 21221.

6. Camp Bravo is a private entity within the meaning of 42 U.S.C. § 12181(6) and is a place of public accommodation within the meaning of 42 U.S.C. § 12181(7); 28 C.F.R. § 36.104.  Camp Bravo is a public accommodation subject to title III of the ADA because it owns, leases (or leases to), or operates a place of public accommodation.  See 42 U.S.C. § 12182(a); 28 C.F.R. § 36.104.