United States of America v. The International Spy Museum - Settlement Agreement

A. BACKGROUND

1. The parties to this Settlement Agreement ("Agreement") are the United States of America Department of Justice ("United States") and the International Spy Museum ("Museum").

2. This Agreement resolves an investigation and compliance review conducted by the United States Department of Justice (the "Department") of the Museum under title III of the Americans with Disabilities Act of 1990, 42 U.S.C. §§ 12181-12189 (the "ADA").

3. The investigation was commenced when the Department received a complaint dated August 14, 2004, from Mr. Michael Byington, the president of the Kansas Association for the Blind and Visually Impaired. Mr. Byington, who is legally blind, alleged that he and a group of individuals who are blind or have low vision were denied full and equal enjoyment of the Museum's goods, services and facilities of the Museum in violation of title III of the ADA. Specifically, Mr. Byington alleged that the Museum's exhibits and programs were inaccessible to visitors who are blind or who have low vision. For example, the Museum did not have guides or docents trained in providing accessible tours or computers equipped with speech outputs. The Museum did not provide printed materials, such as exhibit brochures or program handouts in alternate formats, such as Braille, large print or audio recording. Mr. Byington states that the Museum's failure to design accessible programs and services and thereby ensure that the content of its exhibitions, public programs, and other offerings were accessible and effectively communicated to individuals with vision impairments violated his rights under the ADA.