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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

PANAMA CITY DIVISION

MARIKA MARIS,

Plaintiff,

vs.

BAY HOSPITAL, INC. d/b/a 

Gulf Coast Regional Medical 

Center, HCA Inc.

Defendant.

Case No.: 

COMPLAINT

DEMAND FOR JURY TRIAL

COMES NOW, the Plaintiff, Marika Maris, by and through her undersigned

counsel, brings this lawsuit seeking declaratory relief, injunctive relief and monetary 

damages against Defendant, Bay Hospital, Inc. d/b/a Gulf Coast Regional Medical 

Center (“Gulf Coast”) and HCA Inc. (“HCA”) for violations of Title III of the 

Americans with Disabilities Act, Section 504 of the Rehabilitation Act of 1973 

(“Section 504”), and Section 1557 of the Patient Protection and Affordable Care 

Act (“Affordable Care Act”). Defendants failed to provide effective communication,

and meaningful access for the deaf Plaintiff when she sought medical care nineteen 

(19) times from 2017 to present, when seeking treatment for herself and her minor 

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son. Defendants intentionally denied Plaintiff full and equal enjoyment of 

Defendants’ services, facilities, and privileges. Defendants failed to make 

reasonable modifications in policies, practices or procedures, and failed to take 

such steps as are necessary to ensure the Plaintiff was not excluded, denied 

services, or otherwise treated differently because of her disabilities. 

JURISDICTION AND VENUE

1. This Court has jurisdiction over the actions pursuant to 28 U.S.C. § 

1331, 1343. 

2. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 

1391(b)(1)-(b)(2) because 1.) the Defendants are located in this district, and 2.) a 

substantial part of the events or omissions giving rise to Plaintiff’s claims occurred 

within this district. 

PARTIES

PLAINTIFF

3. Plaintiff, MARIKA MARIS (“Ms. Maris”), is and was, at all times 

material hereto, a resident of Bay County, Florida. Ms. Maris is deaf, and she relies 

upon American Sign Language (“ASL”) to communicate effectively. 

DEFENDANT

4. Defendant, BAY HOSPITAL, INC. d/b/a Gulf Coast Regional 

Medical Center (“Gulf Coast”) is located in Panama City, Florida, and is a place 

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of public accommodation pursuant to 42 U.S.C. §12181 (7) (F), and is subject to 

the mandates of Title III of the ADA and its implementing regulations.

5. Defendant HCA INC., (“HCA”) is the parent corporation of Gulf 

Coast Regional Medical Center, and is located in Nashville, Tennessee. HCA is a 

place of public accommodation pursuant to 42 U.S.C. §12181 (7) (F), and is 

subject to the mandates of Title III of the ADA and its implementing regulations.

6. Gulf Coast and HCA are recipients of federal financial assistance 

and are, therefore, subject to the requirements of Section 504 of the 

Rehabilitation Act, 29 U.S.C. § 794, and its implementing regulations.

7. Defendants are principally engaged in the business of providing 

health care and are, therefore, subject to Section 1557 of the Patient Protection 

and Affordable Care Act, 29 U.S.C. § 705(20) and 42 U.S.C. § 12102. See 42 

U.S.C. § 18116; 45 C.F.R. § 92.4, and its implementing regulations.

FACTUAL ALLEGATIONS

8. Ms. Maris was born deaf, and relies upon American Sign Language 

(“ASL”) to communicate effectively in a bi-directional manner. Ms. Maris can 

speak to some degree, but often her voice is not understood by others, which is 

both frustrating and embarrassing. She cannot lip-read well enough to 

communicate without an interpreter.

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9. When Ms. Maris receives medical treatment for herself, or her minor 

son she requests an ASL interpreter. In order to engage in an interactive exchange 

of medical information, Ms. Maris requires a qualified ASL interpreter.

10. Ms. Maris has significant health issues requiring medical attention to 

include: cardiac problems, physical problems related to anxiety, chronic sinus 

infections, seizures, ongoing infections with a cochlear implant that had been 

removed and a second one that is inoperable, and syncope episodes.

11. Ms. Maris is now a single mother with a minor son, WMB who is four 

(4) years old.

12. On August 14, 2017, Ms. Maris made a report to the Department of 

Children and Families (“DCF”) about suspected child abuse by her ex-husband. As 

a result, a DCF investigation began, and Ms. Maris was required to comply with 

DCF directives and have WMB undergo a series of medical examinations when 

directed by DCF and or medical professionals.

13. Ms. Maris was very concerned for her son who had bruising on his 

leg, and was believed to be shaken by his father. She was also concerned any 

noncompliance to DCF’s demands could result in WMB being removed from her 

custody.

14. Ms. Maris immediately took WMB to see his primary care doctor for 

an examination related to the allegations of child abuse. The primary care doctor 

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directed her to take WMB to Gulf Coast Regional Medical Center (“Gulf Coast”) 

for a full body scan.

15. First Visit to Gulf Coast: On approximately August 17, 2017, Ms. 

Maris’s brought WMB, now two (2) years old, to the emergency room (“ER”) for a 

body scan. Upon her arrival, as she always does when seeking medical care, Ms. 

Maris requested an ASL interpreter. At first, Gulf Coast said an interpreter would 

be provided, but they failed to provide an interpreter.

16. The staff treating Ms. Maris noted in the child’s medical records the 

mother has “profoundly (sic) deafness.”

17. After waiting, Ms. Maris was finally approached by a nurse, and was 

told an interpreter would not be provided. In response, she told the staff she must 

have an interpreter to understand her son’s treatment. The request was denied. 

18. Medical staff began to examine WMB, and Ms. Maris, again,

requested an interpreter. This time, she was told an interpreter would be provided,

but not until after the child’s x-rays were completed.

19. After WMB’s x-rays were complete, Gulf Coast attempted to provide 

an interpreter through Video Remote Interpreting (“VRI”). VRI is a service which 

allows for the sign language interpreter to appear remotely through a computer. 

The VRI equipment used at Gulf Coast consisted of a small iPad, with a small 

screen, attached to a cart on wheels.

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20. The VRI did not work, and the image of the interpreter continued to 

freeze, and black out. The staff, including the doctor, could see the device did not 

work. Gulf Coast then abandoned the VRI device because it did not work.

21. Instead of providing primary consideration to her request for an ASL 

interpreter, as is required by law, Ms. Maris was forced to attempt to type 

messages back and forth with the doctor through his cell phone. This humiliating 

and demeaning approach failed to provide Ms. Maris effective communication 

because she was not able to understand the medical treatment, nor was she able to 

ask questions about injuries to her son.

22. Frustrated and scared for her son, Ms. Maris used her cell phone to 

pull up the names of ASL interpreters in the area that could be called to come 

interpret. Ms. Maris showed these names and telephone numbers to Gulf Coast, but 

Gulf Coast continued to refuse to provide an interpreter.

23. The full body scan was never performed, and Ms. Maris did not 

understand why. She was very concerned because she was directed, specifically,

by her doctor to get the body scan due to the allegations of the baby being shaken.

In the four (4) hours she was there with her son, Gulf Coast failed to provide 

effective communication by way of an onsite interpreter, or other accommodation. 

24. Second Visit to Gulf Coast: After Ms. Maris failed to get the full body 

scan, DCF directed her to return to Gulf Coast on August 30, 2017, to have a CAT 

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scan performed on WMB. This time, Ms. Maris was accompanied by a deaf friend, 

Amanda Hendrix.

25. Upon arrival, Ms. Maris and her friend requested an ASL interpreter, 

but the request was denied. The medical records confirm the hospital was unable to 

provide an exchange of medical information by documenting, “mom is confused 

where scan is to be done.” But Ms. Maris was not confused about the scan, the 

confusion stemmed from the inability of Gulf Coast to effectively communicate 

with the Plaintiff.

26. Gulf Coast asked Ms. Maris’s deaf friend if she could interpret, but 

Ms. Hendrix explained she too had a hearing loss, and is not a qualified interpreter. 

With no other choice, Ms. Hendrix attempted to interpret, but it was too difficult

because she was trying to lip-read Gulf Coast staff and then sign for Ms. Maris. 

Many of the employees were talking too fast, not looking at her, and or wearing

face masks.

27. Gulf Coast admits in the medical records they are unable to 

communicate with Ms. Maris by documenting “[n]eed for follow up (with DCF), 

[w]hen to return to ED, made contact with [DCF] and mom is to f/u when [DCF] is 

able to locate a rep that will be able to communicate with deaf client, no imaging 

today.”

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28. Ms. Maris and her son were denied medical treatment, because the 

hospital failed to provide effective communication to discuss the basis for the scan.

29. Third Visit to Gulf Coast: On December 18, 2017, Ms. Maris brought 

two (2) year old WMB to Gulf Coast ER because he was coughing and had a fever. 

Although Ms. Maris requested an interpreter, Gulf Coast failed to provide an 

interpreter for the treatment.

30. Fourth Visit to Gulf Coast: Ms. Maris sought treatment at the ER on 

January 3, 2018, for heart palpitations, weakness, vomiting, and coughing. During 

this trip, she was accompanied by her father, Nick Maris. 

31. Once they arrived, Ms. Maris and her father requested an interpreter,

but the request was denied. In an effort to obtain an interpreter, Ms. Maris and her

father shared the names of local ASL interpreter referral agencies that can be called 

to secure an interpreter, but Gulf Coast refused to secure an interpreter.

32. In lieu of giving primary consideration to Ms. Maris’s request for an 

ASL interpreter, the staff forced her to attempt to communicate by gesturing and 

typing on a cell phone. This was not effective, and it was degrading.

33. Seeing his daughter in distress, and unable to exchange her medical 

information, Ms. Maris’s father, Nick Maris, attempted to interpret for her, but it

was not effective. 

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34. Nick Maris knows some very basic sign language, but signs extremely 

slow, and often his signs are not comprehensible. Nick Maris does not have the 

skills or the training to “sign” medical information, or explain medical advice. By 

his own admission, his sign language skills are poor at best, and told Gulf Coast 

the same each time he accompanies his daughter.1

35. As a result of Mr. Maris’s poor signing skills, the communication 

breaks down, and Gulf Coast began communicating directly with Ms. Maris’s

father instead of Ms. Maris. This results in Ms. Maris being relegated to a 

bystander in her own medical treatment.

36. Ms. Maris and her father repeat their requests for an interpreter, to the 

doctors and the nurses, and their requests are continually denied. Augmenting the 

fact she is missing all the medical information and exchange, is her constant 

concern an MRI will be performed on her, and expose her to physical harm from 

the MRI.

2

37. Ms. Maris underwent a series of tests to include a CT of her head and 

brain, chest x-rays, and blood work. Gulf Coast documents the inability to 

 1 The fact that Ms. Maris’s parents cannot sign well is common, because ninety 

percent of all deaf children have parents who are not deaf. Found at

https://www.nidcd.nih.gov/health/statistics/quick-statistics-hearing. (last visited 

April 23, 2020). 2

 Due to the age of the inoperable cochlear implant still implanted in her head, Ms. 

Maris cannot be exposed to an MRI. See

www.hopkinsmedicine.org/otolaryngology/specialty_areas/listencenter/resources/

mris-at-hopkins.html. (last visited April 24, 2020).

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exchange medical information with Ms. Maris by noting in her records, “Barriers 

to communicate/learning: Impaired hearing.”

38. Fifth Visit to Gulf Coast: On January 6, 2018, Ms. Maris took her two 

(2) year old son, WMB to the ER for an ear ache. Upon arrival, Ms. Maris 

requested an interpreter, and again, Gulf Coast failed to provide an interpreter. She 

was accompanied by her mother Despo Maris, who also requested an interpreter.

39. WMB was not feeling well, and was very fussy. It was extremely 

difficult to try to tend to the baby, at the same time Ms. Maris was struggling to 

communicate with Gulf Coast staff. Gulf Coast asked Ms. Maris’s mother to 

interpret, but that was not effective.

40. Despo Maris’s first languages are Greek and Arabic, and she is a very 

poor signer. Despo Maris does not know many signs, and cannot relay medical 

information to her daughter. Despo Maris told Gulf Coast she is not a qualified 

interpreter, and although her daughter is deaf, it does not mean she is a qualified 

interpreter, but Gulf Coast continued to refuse to secure an interpreter.

41. Sixth Visit to Gulf Coast: On January 28, 2018, Ms. Maris, and her 

mother, took WMB, now two (2) years old, to the ER because he had a high fever 

again, and a swollen and sore throat.

42. Ms. Maris and her mother requested an ASL interpreter, but the 

request was denied. The child was diagnosed with tonsillitis and provided

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antibiotics. Ms. Maris was concerned because the child had already been 

prescribed antibiotics, but he kept getting a fever and becoming ill, and she wanted 

to ask more questions.

3 Due to the absence of an interpreter, she was unable to 

have all her questions answered.

43. Seventh Visit to Gulf Coast: Ms. Maris returned to Gulf Coast’s ER 

on May 14, 2018, for chest pains, a head ache, eyelid twitching, and an anxiety 

attack. She was accompanied by her deaf friend, Amanda Hendrix. 

44. Both Ms. Hendrix and Ms. Maris requested an interpreter, and the 

request was denied. Ms. Hendrix told Gulf Coast she has the names of some 

interpreters that can be called to interpret, but the staff was evasive, saying 

something to the effect of there is no time, or we are not sure someone will come. 

Ms. Hendrix told them to try, that way they will know for sure, but an interpreter 

was never provided.

45. In lieu of providing an interpreter for the deaf patient, and the deaf 

companion as required by law, Ms. Hendrix was forced to attempt to interpret for 

Ms. Maris. This was not effective, because Ms. Hendrix could not interpret the 

 

In April of 2018, Ms. Maris received a letter from WMB’s pediatrician advising 

her they would no longer treat her son, and she needed to find other care for him. 

She later found out the doctor told the ASL interpreter service, he did want to have 

to pay for interpreters anymore. It was becoming more difficult for Ms. Maris to 

find a provider who would care for her son, and provide an ASL interpreter for her.

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complex medical terms used, and due to her hearing loss, she was unable to hear 

everything that was being said.

46. Ms. Maris underwent several procedures to include an EKG, chest xray, CT of her head/brain, and blood work. Gulf Coast documents in the medical 

records, Ms. Maris is “severely hearing impaired and has a friend here translating”

and she is “profoundly deaf from birth.” The failure to provide an interpreter 

denied Ms. Maris the ability to participate in her medical care.

47. In May of 2018, WMB was being seen by a physician for chronic 

tonsillitis. Ms. Maris was told WMB would require surgery to remove his tonsils

and adenoids, and the surgery would be performed at Gulf Coast.

48. Ms. Maris was adamant with the physician, telling him she is tired of 

not getting interpreters at Gulf Coast, and said she would not consent to the surgery 

scheduled for May 17, 2018, unless ASL interpreters would be provided.

49. Ms. Maris was assured ASL interpreters would be provided for her 

son’s surgery so she could understand the medical treatment, and have all of her 

questions answered. Due to the child’s age, Ms. Maris was told WMB would be 

required to stay overnight.

50. On approximately May 16, 2018, Gulf Coast called Ms. Maris to 

confirm the surgery time, and other last minute surgical related items. During that 

call, Ms. Maris asked Gulf Coast to confirm onsite interpreters would be provided 

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due to the problems with VRI. Gulf Coast told Ms. Maris they would provide ASL 

interpreters.

51. Eighth Visit to Gulf Coast: On May 17, 2018, Ms. Maris went to Gulf 

Coast for the scheduled outpatient surgery for WMB, now two (2) years old, to 

have his tonsils and adenoids removed. Ms. Maris was accompanied by her 

mother, Despo Maris.

52. Miraculously, Gulf Coast secured onsite ASL interpreters for the first 

day. But WMB was scheduled to stay overnight for observation, and Gulf Coast

failed to secure interpreters for the second day. This left Ms. Maris without an

interpreter for the discharge information, along with discussions with the surgeon 

and medical staff.

53. As a result, her mother was forced to try to interpret for Ms. Maris. 

Ms. Maris’s mother does not sign well, and could not interpret the information.

54. Ninth Visit to Gulf Coast: On approximately August 15, 2018, WMB, 

now three (3) years old, was seen by a Gulf Coast pediatrician due to a penile 

nevus. Although requested, no interpreter was provided for Ms. Maris. The 

physician forced her to write back and forth to communicate, which was not 

effective.

55. Ms. Maris was told a biopsy was required on the child’s penis to 

determine if it was cancer, and the procedure would be performed at Gulf Coast. 

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Ms. Maris wanted to make sure interpreters would be provided for the surgery, in 

case she was told it was cancer or appeared to be cancer, and needed to be able to 

communicate. She was also very worried about the child’s potential pain level. The 

pediatrician assured interpreters would be provided.

56. Tenth Visit to Gulf Coast: On approximately August 27, 2018, Ms.

Maris had to bring WMB into the hospital for a preoperative appointment with the 

anesthesiologist, and was again, denied an ASL interpreter.

57. On August 27, 2018, Gulf Coast called to confirm the final details of 

the surgery, and Ms. Maris asked Gulf Coast to confirm onsite interpreters would 

be provided due to the inoperability of the VRI. Ms. Maris was told ASL 

interpreters would be provided. 

58. Eleventh Visit to Gulf Coast: On August 28, 2018, Ms. Maris, her 

mother, and her son, now three (3) years old, arrived at Gulf Coast for the surgery.

Although Gulf Coast told Ms. Maris ASL interpreters would be provided, they 

were not.

59. Ms. Maris arrived at approximately 6:30 a.m. as instructed. Gulf

Coast attempted to use VRI, but again it did not work. Ms. Maris and her mother 

watched as the staff floundered around trying to get the VRI to work, it did not—

and valuable time was passing before WMB’s surgery time. Due to the child’s 

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history of allergic reaction to anesthesia, Ms. Maris wanted to talk clearly with the 

surgical team before WMB was put under anesthesia.

60. The fact that the device was not working was obvious to everyone in 

the room, to include the VRI interpreter who appeared on the screen. The VRI 

interpreter told Gulf Coast the VRI screen was “blacked out”, and they needed to 

secure an onsite interpreter. Mrs. Despo Maris, who can hear, heard the exchange 

between the VRI interpreter and Gulf Coast staff. The VRI interpreter told Gulf 

Coast she could not provide interpreting services because she could not see Ms. 

Maris.

61. The ill trained staff continued to haphazardly stare at the VRI machine 

and continued to waste time, as Ms. Maris became more anxious to talk with the 

medical staff before WMB was put under anesthesia.

62. As a result of the inoperative VRI, Gulf Coast abandoned the device, 

and told Ms. Maris an onsite interpreter would be provided, and would arrive in 

thirty (30) minutes. For the approximate four (4) hours Ms. Maris and her son were

there, Gulf Coast failed to provide an interpreter.

63. Before WMB went into surgery, Ms. Maris frantically used Facebook 

Messenger to contact a local ASL interpreter referral agency, and told them Gulf 

Coast is refusing to provide an onsite interpreter, and the VRI was not working,

again.

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64. Ms. Maris and the interpreter agency began an exchange about how to 

correct the situation. Ms. Maris’s mother then placed a call to the interpreter 

agency to try to find out how they could get help to get an interpreter, because the 

staff at Gulf Coast was ignoring their pleas for an interpreter.

65. Still, prior to WMB going into surgery, the interpreter agency told Ms.

Maris that Dave Coughlin is the Risk Manager at Gulf Coast, and Ms. Maris 

needed to tell the Gulf Coast staff to call Mr. Coughlin so Ms. Maris could get an 

interpreter.

66. Ms. Maris and her mother provided Dave Coughlin’s contact 

information to the Gulf Coast staff. But the staff told Ms. Maris and her mother, 

Mr. Coughlin was called, but there was “no answer.”

67. Regardless of the fact, Ms. Maris asked for an interpreter at her pre-op 

appointments, spoke to Gulf Coast the day before surgery, asked for an interpreter 

when she arrived, and provided the name of the person reported to be the risk 

manager for the hospital, Gulf Coast still failed to secure an interpreter. This denial 

dovetails Gulf Coast's ongoing knowledge that the VRI device does not work, and 

after, they just abandoned the device knowing it does not work.

68. Ms. Maris was now stuck writing back and forth with medical staff, 

which does not provide her an effective way to exchange medical information. Ms. 

Maris was very upset, and felt powerless because there appeared to be no way to 

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get Gulf Coast to respect her rights as a deaf person, and as a mother to have an 

interactive exchange about health care decisions for her son. 

69. Their blatant exclusion and disrespect is outrageous to Ms. Maris and 

her mother. Ms. Maris’s three (3) year old child was about to be put under 

anesthesia and have biopsy on a potentially cancerous mole on his penis. Ms. 

Maris felt completely defeated and disregarded. As a result, Despo Maris was 

forced to try to interpret for Ms. Maris, and again this was not effective.

70. Ms. Maris was also distressed because she saw her mother, Despo 

Maris upset. All of this avoidable stress and exclusion was created because Gulf 

Coast failed to perform the menial task of picking up a phone, and securing an 

onsite ASL interpreter.

71. When Ms. Maris left, she was told the results of the biopsy would be 

shared with her when she met with the surgeon the next week. It was a harrowing 

week, and they renewed a request to have an interpreter for the biopsy results.

72. Twelfth Visit to Gulf Coast: Approximately one week after the 

surgery, Ms. Maris returned to the surgeon’s office, with her deaf ex-husband, at 

Gulf Coast for a follow up visit to learn the results of the biopsy. Gulf Coast, again,

failed to provide an interpreter.

73. Ms. Maris and her deaf ex-husband tried to assist each other to 

understand what the doctor was saying. Ms. Maris was thankful to learn the mole 

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was benign, but was unable to ask more questions about what caused the mole, if it 

would return, and other critical questions due to the failure of not having an 

interpreter.

74. Thirteenth Visit to Gulf Coast: On October 1, 2018, Ms. Maris 

returned to Gulf Coast ER, because her son was running a fever of 104°, and had a 

bad cough. The family recently returned from a two (2) week trip out of the 

country, and WMB was whining and not well. Ms. Maris was concerned the child 

was exposed to something while travelling.

75. Due to Ms. Maris’s experience with Gulf Coast refusing to secure an 

ASL interpreter, her mother went with her, and they were later joined by her deaf 

ex-husband.

76. Ms. Maris, her deaf ex-husband, and her mother requested an ASL 

interpreter, and, as usual, the requests were denied. Gulf Coast wheeled in the 

infamously inoperable VRI, and, once again, it did not work. The screen was 

blacking out, and could not maintain a connection, so Gulf Coast abandoned the 

device.

77. In lieu of giving primary consideration to Ms. Maris’s request for an 

ASL interpreter, the staff attempted to communicate by way of hand written notes.

Writing was not effective, not only because it did not provide an exchange of 

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medical information, but there were two (2) deaf people in the room. Additionally, 

WMB was whining and requiring Ms. Maris’s attention.

78. Due to the child’s travel out of the country, there was a discussion

about viruses and other infections which Ms. Maris had never heard of before. Ms. 

Maris became very concerned, and, as a result of Gulf Coast failure to secure an 

interpreter, her mother was forced to interpret.

79. Her mother, by her own admission to the staff, missed large portions 

of the medical information because she does not know how to sign the medical 

information. The situation was even more challenging for Despo Maris, due to the 

fact that questions were also being asked by Ms. Maris’s deaf ex-husband, and she 

was trying to interpret for two (2) deaf people.

80. The treating nurse was rough with WMB, and told the family a blood 

and urine sample was needed. Ms. Maris tried to explain that if the nurse would 

please slow down, they could work together to get the samples because WMB has 

had samples taken before, and Ms. Maris was able work with her own child to get 

what was needed.

81. Instead, the child was restrained with a sheet by two (2) nurses, and

the nurse attempted to insert a catheter in WMB. His screams were so loud, they 

could be heard by Ms. Maris’s father and sister in the waiting area.

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82. Ms. Maris was extremely upset, and was trying to tell the nurses to 

stop. At one point, she was told, through gestures, if she did not stop interfering,

she would be removed from the room. But Ms. Maris was not interfering, she 

knows her own child, and how to cajole him to get what was needed. But, because 

there was no interpreter provided, no one was able to effectively communicate, and 

the situation degraded quickly.

83. The nurses continued to try to force a catheter in WMB, and the child

continued to scream and cry. Ms. Maris and WMB’s father tried to help hold the 

child. Finally, WMB’s father demanded the nurses stop, because the nurses were 

unable to get the urine sample even though they relentlessly tried to stick the 

catheter in the baby.

84. Upon coaxing of WMB’s parents, the child provided a urine sample 

on his own. Ms. Maris was denied effective communication throughout her child’s

treatment, and deprived of the ability to protect her son from overzealous medical 

staff. The failure of Gulf Coast to secure an interpreter created an interaction that 

needlessly degraded into a very stressful event for the family, and the child.

85. Upon leaving the hospital, Ms. Maris broke down and cried in the car. 

She was enraged to have been prevented from communicating with the staff to the 

detriment of her child. For two (2) weeks after the event, WMB kept telling his 

mother how scared he was at the hospital, and experienced painful urination.

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86. On approximately October 10, 2018, Hurricane Michael hit the 

panhandle of Florida.

87. Fourteenth Visit to Gulf Coast: On November 14, 2018, Ms. Maris 

took WMB, now three (3) years old, to the ER because he fell on his chin, and his 

mouth was bleeding badly. Ms. Maris was accompanied by her deaf friend,

Amanda Hendrix.

88. Ms. Maris and Ms. Hendrix requested an interpreter, and the request 

was denied. Ms. Maris and Ms. Hendrix were told directly the hurricane made the 

VRI service inoperable, and it had yet to be repaired. It was now more than a 

month after Hurricane Michael hit the panhandle, and although Gulf Coast knew

the VRI could not work, they still refused to provide an onsite ASL interpreter.

89. Gulf Coast was unable to communicate with Ms. Maris, and her deaf 

friend. Ms. Hendrix was forced to try to interpret to help Ms. Maris. Ms. Maris was 

not feeling well herself, and the fighting with Gulf Coast to secure an interpreter

exacerbated the situation. An ASL interpreter was never provided during the 

child’s treatment.

90. During WMB’s treatment, Ms. Hendrix encouraged Ms. Maris to be 

seen since she had not been feeling well, and did not look well. 

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91. Fifteenth Visit to Gulf Coast: Once WMB’s treatment was done, Ms. 

Maris stayed to be examined. Ms. Maris had mastoid pain, and had been spitting 

up blood and coughing.

92. Once seen, Ms. Maris was immediately admitted to Gulf Coast,

requiring hospitalization for three (3) days for Sepsis and Acute Mastoiditis. 

93. For her own treatment, Ms. Maris and Ms. Hendrix renewed the 

request for an ASL interpreter with the nurses and the doctor. Gulf Coast continued

to refuse to provide an interpreter either through VRI, or by way of an onsite 

interpreter. 

94. Later, Ms. Maris’s parents arrived, and renewed the request for an 

interpreter. Nick Maris provided the names of interpreter agencies that could be 

called to obtain an interpreter, but Gulf Coast failed to perform the menial task of 

picking up the phone and calling an ASL interpreter.

95. The barrier created by Gulf Coast required Ms. Hendrix and Ms. 

Maris’s parents to try to interpret, but it was ineffective. The records reflect

information was obtained “through interpretation from the family through lipreading from the patient.” Yet, in the same records, Gulf Coast documented, “She 

appears to try to lipread, but does so poorly.”.

96. During the three (3) day stay, Ms. Maris underwent blood work, an

ECG, chest x-rays, CT of the chest, a maxillofacial CT, and other complicated

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procedures. Ms. Maris’s father was very upset because the doctors began 

discussing a mass found in Ms. Maris’s head that was potentially cancer. An 

interpreter was needed.

97. As Gulf Coast was talking about a possible cancer diagnosis, Ms.

Maris's parents were extremely concerned for her, and didn’t want her to worry. 

Her parents made a difficult, but conscious decision not to attempt to interpret any 

information about a possible cancer diagnosis. Therefore, Ms. Maris was not aware 

that cancer had been discussed until after being released from the hospital several

days later.

98. Ms. Maris’s parents stayed as long as they could each day, knowing 

Gulf Coast had no intention of securing an interpreter for their daughter. Ms. Maris 

was not well, and had no energy to keep fighting to get an interpreter. While her 

parents were not present, Gulf Coast performed some tests, but because Ms. Maris 

was left without any help to communicate, she did not understand what Gulf Coast 

was saying about the tests, or why they were done. Ms. Maris was also afraid they 

would expose her to an MRI, because throughout the treatment MRI’s were being 

discussed. Gulf Coast’s failure to accommodate Ms. Maris made a stressful 

situation untenable.

99. Throughout her entire three (3) day admission, an ASL interpreter was 

never provided.

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100. Sixteenth Visit to Gulf Coast: On January 28, 2019, Ms. Maris

brought WMB, now three (3) years old, to the ER because he was vomiting with 

diarrhea, and had stomach pain. Upon arrival, she requested an interpreter, but the 

request was denied.

101. It was very difficult to tend to WMB, a sick child, and struggle to 

communicate. Although the medical records reflect the doctor documented Ms. 

Maris was “deaf”, Gulf Coast, on information and belief, forced Ms. Maris to 

attempt to communicate by paper and pen. This was not effective, and impossible

to do while tending to her sick child.

102. The child was diagnosed with the flu, and Ms. Maris was very 

concerned because WMB had not been drinking enough liquids, and was afraid he 

would become dehydrated. She was unable to ask questions about the time the 

child would need to recover, and what she should expect next of his condition.

103. Seventeenth Visit to Gulf Coast: On August 19, 2019, Ms. Maris was 

brought to the ER by way of an ambulance, after becoming unconscious and 

passing out on the floor. Ms. Maris was admitted to the hospital for three (3) days, 

and Gulf Coast failed to provide an interpreter for the full admission. Gulf Coast 

tried to use VRI, but it did not work, and is quickly abandoned.

104. During this stay, she had a number of procedures to include chest, hip,

and shoulder x-rays, CT of Head/Brain, EEG, and CT scan of neck, but an 

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interpreter was not provided upon repeated requests by her, her deaf friend, and her 

parents.

105. Gulf Coast documents in the medical records that Ms. Maris is “deaf 

non speaking” and that she is “well known” by the physician screening her. The 

notes further reflect Gulf Coast’s plan to keep her there several days—yet, no one 

secured an interpreter for the three (3) days she was there.

106. Although Ms. Maris had been told the VRI would not work because 

the internet was down, Gulf Coast provided a telemedicine evaluation by way of 

video by a doctor at another location. When the TV is brought in, the family is

confused, and assumed the hospital was going to try VRI again, but, instead, is 

faced with a physician, believed to be a Neuropsychiatrist, who said they must

evaluate Ms. Maris. 

107. There was no interpreter present for this important evaluation, and it 

was approximately 11:00 p.m. Ms. Maris’s deaf friend is forced to interpret

because Gulf Coast failed to provide any way to communicate for the important

evaluation.

108. The communication was not effective, because the deaf friend could 

not hear everything the doctor on the screen was saying, while concurrently trying 

to interpret what the parents were saying. The deaf friend missed a great deal of 

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information, and told the doctor he could not hear everything being said by the 

doctor or by the parents.

109. It was unclear to Ms. Maris how Gulf Coast had sufficient internet to 

provide the telemedicine service, a service which they shall charge the patient. Yet,

insufficient internet to provide operable VRI, a service which they cannot charge to 

the patient, but will provide effective communication with the patient. The family 

was very frustrated, and Ms. Maris was humiliated and felt desperate to talk with 

the doctors, and answer their questions so they could uncover the nature of her 

medical condition. Ms. Maris was very ill, and unable to walk, and the frustration 

of being unable to communicate exacerbated her stress and anxiety level.

110. Due to the fact that Gulf Coast never secured her an interpreter, and 

the family’s ongoing fears they will try to give Ms. Maris an MRI, her mother slept

over every night she was admitted. 

111. Gulf Coast notes in Ms. Maris’s medical records, “[patient] would 

have liked to have a sign language interpreter during her stay but the internet is 

down since the storm.” This entry is made by Gulf Coast almost one (1) year after

Hurricane Michael hit the panhandle of Florida.

112. Eighteenth Visit to Gulf Coast: After being discharged from Gulf

Coast, Ms. Maris had not yet fully recovered, she lost strength on the left side of 

her body, and could not walk without assistance. She was told to go for physical 

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therapy. On information and belief, when the appointment was made, her mother

requested an interpreter over the phone.

113. On August 27, 2019, Ms. Maris attended her physical therapy 

appointment with her parents and her deaf friend. Upon arrival, they asked when

the ASL interpreter would arrive, but no interpreter was secured.

114. Ms. Maris was using a wheelchair at this time, and she was anxious to 

undergo the physical evaluation, and was forced to her have her deaf friend 

interpreter. This was not effective, because the physical therapist had questions 

about some of the neurological issues Ms. Maris was having. A qualified ASL 

interpreter was needed.

115. On approximately August 5, 2019, Ms. Maris was prescribed and 

fitted with an ambulatory EEG monitor to be worn to monitor seizures and cardiac

activity. During that appointment, not held at Gulf Coast, Ms. Maris was provided 

an ASL interpreter.

116. Nineteenth Visit to Gulf Coast: On September 19, 2019, Ms. Maris 

had approximately thirteen (13) seizures, and her family drove her to the ER at 

Gulf Coast.

117. Once again, Ms. Maris, and her parents requested interpreters and the 

requests were denied. Ms. Maris underwent a series of testing to include EKG, 

blood work, x-rays, and CT of her head/brain, all without the benefit of an ASL 

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interpreter. Ms. Maris continued to have seizures while at the hospital, and a 

qualified ASL interpreter was needed.

118. Her parents attempted to interpret for Ms. Maris, but that was not 

effective. Ms. Maris was very concerned for her health, and was unable to 

participate in her own health care decisions due to the failure of Gulf Coast to 

secure an interpreter. 

119. To properly frame the pattern and practice of exclusion experienced

by the Plaintiff, Ms. Maris was denied an interpreter from the time she entered the 

hospital, when required to provide informed consent, throughout the medical 

treatment, and when discharged with instructions on what she must do next.

120. On information and belief, there are at least four (4) ASL interpreter 

referral agencies that provide interpreters in the Bay County area. These agencies

are known to Gulf Coast, because the family, the patient, and her friends were 

continually providing the information to Gulf Coast in the hopes they would secure 

an interpreter.

121. The doctors and the nurses could see the VRI was not working, 

because it would freeze, which caused the staff to continuously disconnect the 

VRI, and then abandon the device. 

122. Doctors and nurses who attempted to communicate with Ms. Maris 

knew of the communication difficulties, because they documented the difficulties 

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in the medical records. The records also show many of the same medical providers 

were involved with the pattern and practice of denials of an ASL interpreter.

Medical records documented by Gulf Coast report there is a “barrier to 

communication/learning” because she is deaf. 

123. Gulf Coast also documented her “preferred spoken language” and 

“preferred written language” is ASL. But still repeatedly fails to accommodate her 

language and disability needs.

124. Gulf Coast provided less information to, and received less information 

from Ms. Maris than typically received from other similarly situated individuals.

This stems from their repeated failure to perform the menial task of picking up the 

phone and calling an ASL interpreter.

125. The medical records created by Gulf Coast include an affirmative 

disclosure by the hospital, which Ms. Maris must execute, that acknowledges her 

legal right to be “treated with respect and dignity and without discrimination or 

distinction based on age, gender, disability, race, color ancestry..., or any other 

basis prohibited by law.” Yet, they engage in a practice and pattern of violating her 

federally protected rights over and over again.

126. After continuous violation of her federally protected rights, Ms. Maris 

was humiliated and furious over the blatant denial to allow her the benefit of 

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engaging in an exchange of her medical information. Ms. Maris was continuously 

denied an onsite interpreter, even when the VRI continued to be inoperable. 

127. Ms. Maris was upset, stressed, disappointed, and incensed that she 

was treated with such disregard, and was not provided meaningful access to her

own, and her child’s medical care. 

128. Ms. Maris shall continue future use of Gulf Coast as it is a hospital 

covered by her health insurance, and less than ten (10) minutes from her home. 

Further, Gulf Coast has extensive pediatric services which are needed for WMB.

129. The Plaintiff experienced humiliation, dejection, embarrassment, 

anger, frustration, and fear as the direct result of Defendants’ violation of her 

federally protected rights.

130. Defendants’ actions have caused the Plaintiff distinct, palpable, and 

perceptible injury. Those injuries include, but are not limited to, those described 

herein.

Count I

Title III of the Americans with Disabilities Act

131. Plaintiff repeats and re-alleges allegations ¶¶ 1-130 in support of her 

claims.

132. Plaintiff, in this Count, requests declaratory and injunctive relief

pursuant to Title III of the ADA.

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133. Defendants are entities covered by Title III of the ADA, 42 U.S.C. § 

12101, et seq, and places of public accommodation, as defined by Title III of the 

ADA, 42 U.S.C. § 12181(7), 28 C.F.R. § 36.104.

134. Defendants’ actions and omissions violate their duty to ensure that no 

individual shall be discriminated against on the basis of disability in the full and 

equal enjoyment of the goods, services, facilities, privileges, advantages, or 

accommodations of any place of public accommodation by any person who owns, 

leases (or leases to), or operates a place of public accommodation.

42 U.S.C. § 12182.

135. Defendants failed to make reasonable modifications in policies, 

practices, or procedures, when such modifications are necessary to afford such 

goods, services, facilities, privileges, advantages, or accommodations to 

individuals with disabilities. 42 U.S.C. §§ 12182 (2) (A) (ii).

136. Defendant failed to take such steps as may be necessary to ensure that 

no individual with a disability is excluded, denied services, segregated or otherwise 

treated differently than other individuals because of the absence of auxiliary aids

and services, unless the entity can demonstrate that taking such steps would 

fundamentally alter the nature of the good, service, facility, privilege, advantage, 

or accommodation being offered or would result in an undue burden. 42 U.S.C. § 

12182 (2) (A) (iii). (emphasis added).

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137. The term "auxiliary aids and services" includes: “Qualified 

interpreters on-site or through video remote interpreting (VRI) services, notetakers; 

real-time computer-aided transcription services; written materials; exchange of 

written notes...accessible electronic and information technology; or other effective

methods of making aurally delivered information available to individuals who are 

deaf or hard of hearing.” 28 C.F.R. § 36.303 (b) (1). (emphasis added).

138. In order to be effective, auxiliary aids and services must be provided 

in accessible formats, in a timely manner, and in such a way as to protect the 

privacy and independence of the individual with a disability. 28 C.F. R. § 36.303 

(c) (1) (ii).

139. A qualified interpreter means an interpreter who, via a video remote 

interpreting (VRI) service or an on-site appearance, is able to interpret effectively, 

accurately, and impartially, both receptively and expressively, using any necessary 

specialized vocabulary. 28 C.F.R. § 36.104.

140. A public accommodation shall not require an individual with a 

disability to bring another individual to interpret for him or her. 28 C.F. R. § 

36.303 (c) (2).

141. A public accommodation that chooses to provide qualified interpreters

via Video Remote Interpreting [VRI] service shall ensure that it provides—

(1) Real-time, full-motion video and audio over a dedicated high-speed, wideCase 5:20-cv-00136-MW-MJF Document 1 Filed 05/01/20 Page 32 of 39
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bandwidth video connection or wireless connection that delivers high-quality video 

images that do not produce lags, choppy, blurry, or grainy images, or irregular 

pauses in communication; (2) A sharply delineated image that is large enough to 

display the interpreter's face, arms, hands, and fingers, and the participating 

individual's face, arms, hands, and fingers, regardless of his or her body position;

(3) A clear, audible transmission of voices; and (4) Adequate training to users of 

the technology and other involved individuals so that they may quickly and 

efficiently set up and operate the VRI. 28 C.F.R. § 36.303.

142. Defendants have engaged in an ongoing pattern and practice of

discrimination by continually violating Ms. Maris’s federally protected rights.

143. As a result of Defendants’ actions described above, Plaintiff suffered 

irreparable loss and injury including, but not limited to, humiliation, 

embarrassment, emotional distress, and a deprivation of her rights to nondiscrimination on the basis of her disabilities. In engaging in this unlawful conduct 

described above, Defendants acted maliciously to damage the rights and dignity of 

Plaintiff.

WHEREFORE, Plaintiff requests the relief set forth below.

COUNT II

SECTION 504 OF THE REHABILITATION OF 1973

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144. Plaintiff incorporates and re-alleges paragraphs ¶¶ 1-130 in support of 

her claims.

145. Plaintiff in this Count requests declaratory relief, permanent 

injunctive relief, and monetary damages pursuant to Section 504.

146. Ms. Maris is deaf, and her disabilities substantially limit major life 

activities and she is, therefore, considered to be an individual with a disability 

under Section 504.

147. Count II is brought against the Defendants as a claim for 

discrimination against people with disabilities in violation of Section 504 of the 

Rehabilitation Act of 1973, 29 U.S.C. §794, which provides, in relevant part:

No otherwise qualified individual with a disability in the United 

States, as defined in Section 705 (20) of this title, shall, solely 

by reason of his or her disability, be excluded from the 

participation in, be denied the benefits of, or be subjected to 

discrimination under any program or activity receiving Federal 

financial assistance. 

148. Defendants are recipients of federal financial assistance including, but 

not limited to, acceptance of Medicare and Medicaid funds, and are, therefore, 

subject to the requirements of Section 504. 29 U.S.C. § 794.

149. Defendants have intentionally discriminated against Plaintiff on the 

basis of her disabilities, in violation of 29 U.S.C. §794 and its implementing 

regulations. Such discrimination includes, but is not limited to, failure to provide 

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auxiliary aids and services, denial of effective communication, and exclusion to 

services based on disability. 45 C.F.R § 84.52.

150. A recipient hospital that provides health services or benefits shall 

establish a procedure for effective communication with persons with impaired 

hearing for the purpose of providing emergency health care. 45 C.F.R. § 84.52.

151. Defendants’ actions were intentional and with reckless disregard for 

the rights of the Plaintiff who made repeated affirmative requests to be 

accommodated, as did her family members.

152. As a result of Defendants’ actions described above, Plaintiff suffered 

irreparable loss and injury including, but not limited to, humiliation, 

embarrassment, emotional distress, and a deprivation of her rights to nondiscrimination on the basis of her disabilities. 

153. Defendants have engaged in an ongoing pattern and practice of

discrimination by continually violating Ms. Maris’s federally protected rights.

154. In engaging in this unlawful conduct described above, Defendants 

acted intentionally and maliciously to damage the rights and dignity of the 

Plaintiff.

WHEREFORE, Plaintiff requests the relief set forth below.

COUNT III

SECTION 1557 OF THE PATIENT PROTECTION AND 

AFFORDABLE CARE ACT

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155. Plaintiff incorporates and re-alleges paragraphs ¶¶ 1-130 as it fully set 

forth herein.

156. Plaintiff, Ms. Maris, is substantially limited in the major life activities 

of hearing and speaking. Accordingly, she is an individual with a disability as 

defined under 29 U.S.C. § 705(20) and 42 U.S.C. § 12102. See 42 U.S.C. § 18116; 

45 C.F.R. § 92.4.

157. Defendants are a “healthcare program or activity,” receiving federal 

financial assistance, including Medicaid and Medicare reimbursements. They are, 

therefore, a covered entity under 42 U.S.C. § 18116.

158. Section 1557 of the Patient Protection and Affordable Care Act states 

“an individual shall not, on the ground prohibited under . . . section 504 of the 

Rehabilitation Act of 1973 (29 U.S.C. § 794), be excluded from participation in, be 

denied the benefits of, or be subjected to discrimination under, any health program 

or activity, any part of which is receiving Federal financial assistance[.]”. 42 

U.S.C. § 18116(a).

159. A public entity shall give “primary consideration” to the requested 

accommodation by individuals with disabilities. 45 C.F.R. § 92.202. See 28 C.F.R

§ 35.160 (b) (1) (2).

160. A qualified interpreter for an individual with a disability means an 

interpreter who via a remote interpreting service or an on-site appearance:

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(i) Adheres to generally accepted interpreter ethics principles, including client 

confidentiality; and (ii) is able to interpret effectively, accurately, and impartially, 

both receptively and expressively, using any necessary specialized vocabulary, 

terminology and phraseology. 45 C.F.R. § 92.4.

161. Defendants have engaged in an ongoing pattern and practice of

discrimination by continually violating Ms. Maris’s federally protected rights.

156. Defendants have intentionally discriminated against the Plaintiff 

solely on the basis of her disabilities, in violation of Section 1557 the Patient 

Protection and Affordable Care Act, 42 U.S.C. § 18116.

157. As a result of Defendants’ actions described above, Plaintiff 

suffered irreparable loss and injury including, but not limited to, humiliation, 

embarrassment, emotional distress, and a deprivation of her rights to nondiscrimination on the basis of her disabilities. In engaging in this unlawful conduct 

Defendants acted intentionally and maliciously to damage the rights and dignity of 

the Plaintiff.

WHEREFORE, Plaintiff requests the relief set forth below

Relief Requested

WHEREFORE, Plaintiff respectfully requests the following relief:

A. The Court assume jurisdiction;

B. Issue a declaratory judgment that Defendants’ policies, procedures, 

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and practices have subjected Plaintiff to discrimination in violation of 

Title III of the Americans with Disabilities Act, Section 504 of the 

Rehabilitation Act of 1973, and the Affordable Care Act;

C. Enjoin Defendants from any policy, procedure, or practice that will 

deny deaf individuals, such as the Plaintiff, equal access to an

opportunity to participate in, and benefit from, Defendants’ services, 

or that denies Plaintiff effective communication with Defendants;

D. Order Defendants to train its employees about Plaintiff’s rights, and 

the rights of individuals who are deaf, about the requirements to 

provide auxiliary aids and services, including providing qualified sign 

language interpreters;

E. Award compensatory damages to the Plaintiff for violation of Section 

504 and the Affordable Care Act; 

F. Award reasonable attorney’s fees, and expenses and costs of suit; and

G. Grant such other relief as the Court may deem equitable and just 

under the circumstances.

DATE: May 1, 2020.

Respectfully submitted,

MORGAN AND MORGAN

/s/ Sharon Caserta

Sharon Caserta, Esq.

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Florida Bar No.: 0023117

Morgan & Morgan

Deaf /Disability Rights 

76 South Laura Street, Suite 1100

Jacksonville, FL 32202

(904) 245-1121 (Videophone)

(904) 361-0078 (Voice)

(904) 361-4305 (Facsimile)

scaserta@forthepeople.com

Trial Counsel for Plaintiff

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