Before getting started on the blog entry for the week, a housekeeping matter in order. Next week, I move my daughter in for her final year of college. So, it is entirely possible that I will not have a blog entry next week. I will definitely be back blogging the week after.

Turning to

The ADA just had its 36th year anniversary. Happy anniversary!! In June, I got to visit the George H.W. Bush presidential library where his signing of the ADA is featured prominently. It was pretty neat to see that. Interestingly enough, many years ago when I visited the George W. Bush presidential library in Dallas, Texas,

Before getting started on the blog entry for the week, if anybody is interested in the journey I took to get to my law and consulting practices, I discussed that journey in this article.

This week’s blog entry is an update on a case that we previously blogged on here, Payan v,

Before getting started on the blog entry of the week, a housekeeping matter, I am thinking that there may be one additional substantive blog for the rest of the year before I do the 2025 greatest hits. My thinking is that one more substantive blog entry after this will appear the week of December 8.

Today’s blog entry is a published decision from the Third Circuit, Montanez v. Price, here decided on October 8, 2025 (which was my birthday). It discusses a series of issues, including: the Eighth Amendment; what is a program, service, and/or activity; and nondelegable duty. More specifically, the blog entry is divided into the following  categories