02 Legal Exposure
| Framework | Applicability | Deadline | Risk | Exposure |
|---|
| Colorado HB21-1110 | Direct — $3,500/violation; state instrumentality via 24 districts | Expired July 2025 | VERY HIGH | $150,500 |
| HHS Section 504 | Direct — Medicaid waivers + CDE; ~210 employees. 12–18 months lead time needed. | May 11, 2026 | VERY HIGH | $15M+/yr |
| DOJ Title II | Indirect — "flow-down" to contractors; 24 districts updating procurement | April 24, 2026 | HIGH | Contract terminations |
| ADA Title III | Direct — nonprofit = public accommodation | Ongoing | HIGH | $5K–$270K/suit |
"Good Faith" Defense — Forfeited
The original HB21-1110 deadline was July 1, 2024. HB24-1454 extended it to July 1, 2025 — but only for entities demonstrating good faith. A website with lorem ipsum, broken contact links, and zero keyboard-completable tasks in February 2026 — 7 months past the grace period — demonstrates the opposite. This strips Laradon of its legal shield.
Critical Legal Concepts
5,500+
Projected 2026 lawsuits
- "Flow-Down" Liability: School districts' Title II obligations flow down to contractors. Laradon's non-compliance risks contract termination from 24 districts.
- "Non-Delegable Duty": Laradon retains liability for third-party tools (EveryAction, ApplyToJob, EdTech). Outsourcing a function doesn't outsource the obligation.
- "Nexus" Theory: Plaintiffs target connection between digital barriers and physical services — proven in 7th Circuit and NY, FL, CA. Laradon's site is transactional.
- HHS OCR Enforcement: Can investigate, mandate corrective action, and terminate federal funds. Existential financial risk.
Illustrative Cases
| Case | Year | Relevance |
|---|
| Robles v. Domino's Pizza (9th Cir.) | 2019 | Title III web/app claim allowed without DOJ regs |
| NFB v. Scribd (D. Vt.) | 2015 | Online service = public accommodation |
| NAD v. Netflix (D. Mass.) | 2012 | Title III applies to streaming; caption access |
| Blind users v. Girl Scouts | 2020 | Nonprofit-adjacent youth-serving entity targeted |