The Rising Tide of ADA Litigation Against Health Care Entities

by Mintz Levin - Employment Matters
Contact

Over the past several years, health care entities have increasingly become the target of private and government plaintiffs complaining of disability discrimination. A crescendo of litigation has engulfed the health care industry—and most notably of late, “drive-by” litigation attacking the perceived failure of health care entity facilities and websites to accommodate the needs of persons with disabilities consistent with the requirements of the Americans with Disabilities Act (ADA).

Read the full article below or here: The Rising Tide of ADA Litigation Against Health Care Entities (©Copyright 2018, American Health Lawyers Association, Washington, DC. Reprint permission granted.)

Disability rights advocates seem to perceive ADA-based litigation against health care entities as low-hanging fruit. But why? Do health care entities discriminate against disabled person at a higher rate than other employers and businesses? Or is it that government agencies and plaintiffs can make an easy example out of health care entities because of the ostensible irony of a health care entity refusing to accommodate the needs of someone with health challenges? Comments by an Equal Employment Opportunity Commission (EEOC) attorney in the context of one case the EEOC filed against a health care organization seem to support the latter explanation:

Sometimes it looks like organizations engaged in the health care field or in the performance of other “good works” consider it impossible for them to have discriminated—or to be challenged for having discriminated—particularly when it comes to the ADA.

The Americans with Disabilities Act

Passed in 1990 and amended in 2008, the ADA prohibits discrimination on the basis of disability in employment, services offered by public entities (including public transportation), public accommodations (including commercial facilities), and telecommunications. In addition to its nondiscrimination requirements, the ADA affirmatively requires employers and businesses to provide reasonable accommodations to qualified individuals with a disability. Title I applies to employers; Title III applies to places of public accommodation and commercial facilities (including many health care entities such as medical offices, hospitals, and nursing homes). The ADA also importantly protects people against discrimination because they are regarded as disabled or have a record of a disability.

Title I prohibits employment discrimination on the basis of disability. It also requires employers to provide reasonable accommodations to employees who can perform the essential functions of a job with the aid of such an accommodation. Some examples include providing scheduling accommodations to a nurse that is undergoing chemotherapy for breast cancer or offering a nursing home janitor with diabetes extra breaks to ensure his insulin levels remain healthy through the day. Often, these accommodations cost the employer very little.

A reasonable accommodation is one that does not place an undue burden on the employer; while cost is not the only factor in determining whether an accommodation does not unduly burden an employer, it plays a major role.

Nonetheless, the cost of failing to provide a reasonable accommodation will almost certainly outweigh the cost of making the accommodation. The ADA provides aggrieved employees with a damages toolkit that includes lost wages (both back pay and front pay), compensatory and punitive damages, prejudgment interest, and reasonable attorneys’ fees and litigation costs. Title III prohibits discrimination on the basis of disability in the activities of places of public accommodations (businesses that are generally open to the public and that fall into one of 12 categories listed in the ADA, which includes many health care entities) and requires newly constructed or altered places of public accommodation—as well as commercial facilities (privately owned, nonresidential facilities)—to comply with the ADA standards. Title III endeavors to make facilities and websites accessible to those with disabilities.

EEOC Enforcement and Employment Litigation Under Title I

The EEOC enforces Title I of the ADA. The EEOC reports that it received more charges of disability discrimination in 2016 than it had in its history, and 2017 saw only a slight decrease in that number. In 2017, the one medical condition that drove a plurality of ADA discrimination complaints was anxiety disorder, representing 8.2% of all disability discrimination complaints received by the EEOC. Depression also ranked highly among disability indications at a shade over 7% of all charges.

Emotional and mental disabilities (such as anxiety disorder, depression, and ADHD) are among the least understood. Rather than engage employees in an interactive process to determine whether reasonable accommodations for these disabilities are possible, many employers do not actively address the problem. Employers should engage employees who disclose mental or physical disabilities in a good faith interactive process to discover a mutually acceptable accommodation. An employer must accommodate a disabled employee if the accommodation would not create an undue burden on the employer. Employers also must understand that there’s no one-size-fits-all approach when it comes to leave policies and accommodations involving leave.

The 2008 amendments to the ADA broadened the law’s definition of disability to include virtually any chronic or serious health condition. In addition, in late 2017, the EEOC made it easier for an employee to commence the charge process by opening an online public portal to submit inquiries to the EEOC.

Over the last several years, EEOC enforcement activity against health care employers has increased. For example, in February 2018, the EEOC announced a lawsuit against West Meade Place LLP, which operates a skilled nursing and rehabilitation center in Nashville, TN. The company allegedly refused to provide a reasonable accommodation to an employee who suffers from an anxiety disorder, and then fired her because of her disability. According to the complaint, West Meade hired the employee as a laundry technician in February 2015. When the employee requested leave as a reasonable accommodation for her anxiety disorder in November 2015, management told her she could not take leave because the Family and Medical Leave Act did not apply to her. West Meade then required the employee to obtain and return to management a note from her doctor, clearing her to return to work without any restrictions, less than 36 hours after the employee requested a reasonable accommodation for her disability. When the employee could not quickly obtain a doctor’s note, West Meade discharged her. The EEOC is seeking injunctive relief prohibiting West Meade from discriminating against employees based on their disabilities, as well as back pay and compensatory and punitive damages for the former employee.

In 2014, the EEOC sued a Michigan nonprofit called Disability Network, whose primary function is to provide services to people with disabilities. The EEOC alleged that Disability Network denied a deaf employee, who worked as an independent living specialist for the nonprofit, reasonable accommodations such as TTY equipment, a video phone, and the ability to use text messaging. The complaint also alleged that Disability Network rejected the employee’s requests, failed to provide him with alternate accommodations, and finally fired him because he is deaf. The EEOC ultimately settled with Disability Network, which agreed to pay $38,500 in monetary relief and sign a five-year consent decree with the EEOC that provides for training on the ADA and enjoins Disability Network from terminating any employee on the basis of disability or failing to provide reasonable accommodations. Consent decrees often result in EEOC oversight and audit of an employer’s practices for several years.

EEOC trial attorney Nedra Campbell said of Disability Network:

The hypocrisy of this non-profit—whose very mission is to help disabled individuals—disadvantaging and then firing someone because of a disability—is mind-boggling . . . Disability Network,
of all people, should understand the importance of working toward reasonable accommodations for a deaf employee. It only goes to show that the EEOC has its work cut out for it—and we will certainly continue our fight for the rights of the disabled.

In another case, the EEOC announced a settlement with a nationwide dialysis provider to end an ADA discrimination and failure to accommodate suit. The provider agreed to pay $190,000 to a former nurse with breast cancer who it allegedly fired and then refused to rehire because she asked for more medical leave to complete her chemo treatment following mastectomy surgery. The EEOC claimed that the company terminated her after four months, telling her that she exceeded the time limit set out in its medical leave policy, despite the fact that the nurse was on approved medical leave and her doctor approved her return to work without restrictions. Commenting on the case, an EEOC attorney noted:

Extending her medical leave would have posed little burden… Employers with inflexible leave policies lose the opportunity to help a valued employee return to work.

Other examples of EEOC enforcement activity against health care employers involve cases that show how often employers may bungle employees’ requests for leave as a reasonable accommodation. A Dallas home health care company paid $25,000 for allegedly discriminating against an employee with bipolar disorder by firing her when she requested leave to see her health care provider. In another example a Mississippi provider of inpatient and outpatient health care services agreed to pay $85,000 to settle a disability case of a therapist who allegedly was denied several weeks of additional leave and fired after liver transplant surgery. Finally, the EEOC sued a Georgia regional medical center alleging that it fired a medical records analyst who requested two weeks of leave due to a medical condition that caused her to faint at the hospital.

Drive-By and Website Accessibility Litigation Under Title III

A spike in Title III litigation (and litigation under state analogs to the ADA) seems to have arisen out of what has been dubbed “drive-by lawsuits” or “Google lawsuits.” In 2014, the Wall Street Journal reported that Title III lawsuits increased 55% from the prior year. In addition, “the Department of Justice, which enforces Title III, received 6,391 accessibility complaints in fiscal year 2015 –representing a 40% increase over claims in the prior fiscal year.”

Under Title III, almost anyone who lives with a disability can sue a place of public accommodation (including hospitals, physician practices, clinics, and other health care entities open to the public) for a perceived failure to comply with the ADA’s requirement to accommodate disabled customers. According to some reports, plaintiffs (or attorneys) are able to spot perceived ADA violations simply by driving by an establishment and then claiming that he or she was unable to access the facility due to the violation—giving rise to the term “drive-by lawsuit.” So-called “Google lawsuits” arise from identifying accessibility deficiencies on facility grounds using imaging technology such as Google Maps or Google Earth; for example, if a clinic’s parking lot doesn’t provide sufficient handicap parking spaces. The most challenging new area of focus, however, involves website accessibility, which often adversely impacts visually and hearing-impaired persons.

While Title III limits liability to injunctive relief and attorneys’ fees and costs, its complicated regulatory regime has spurned a cottage legal industry filing lawsuits against businesses. Many businesses that are the subject of these lawsuits may have never received a complaint from a disabled customer and try to be diligent about ADA compliance. In fact, the costs to defend against Title III litigation often far exceed the cost of having a comprehensive ADA compliance program in place. Title III creates opportunities to foreclose claims by eliminating barriers promptly or through a comprehensive remediation plan.

The Rising Tide of Website Inaccessibility Litigation

Website accessibility litigation is on the rise—2017 saw a major spike, with the filing of approximately 800 federal suits and over 100 state court suits.

The first trial involving a website accessibility lawsuit is believed to have occurred in 2017. In Gil v. Winn-Dixie Stores, Inc., a federal district judge in Florida concluded that the grocery store chain’s website was inaccessible to visually impaired individuals in violation of Title III of the ADA. The court ordered Winn-Dixie to conform its website to the Web Content Accessibility Guidelines 2.0 AA (WCAG 2.0 AA).

The WCAG 2.0 AA contains technical standards for web content accessibility that meet the needs of individuals, organizations and governments internationally. Regulations promulgated in 2016 by the U.S. Department of Health and Human Services under the Affordable Care Act and Medicaid require covered entities providing health care programs and services to have accessible electronic information technology, including accessible websites that conform to WCAG 2.0 AA.

In 2016, Tenet Healthcare, which operates several Florida hospitals, was named in a class action complaint on behalf of a putative class of blind individuals; the case settled as a result of mediation within a few months of the filing of the complaint. The complaint alleged that the hospitals’ websites were not accessible to blind individuals using screen-reader technology in violation of Title III of the ADA as well as Section 504 of the Rehabilitation Act. CAC Florida Medical Centers also was sued over website accessibility by a blind individual, but that case was dismissed.

WellPoint agreed to a public settlement that requires modifications to its websites and apps to bring them in conformance with WCAG 2.0 AA.

What Should Health Lawyers Do Now?

To protect against possible exposure, health care counsel should advise their clients to review the WCAG 2.0 AA standards and engage an experienced website accessibility consultant to help with this sophisticated process. And in the event a health care organization or its affliates receive a demand letter from an attorney, private party, or government agency alleging website noncompliance with Title III, they should take immediate action, working with those experienced in responding to and litigating under Title III.

©Copyright 2018, American Health Lawyers Association, Washington, DC. Reprint permission granted.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Mintz Levin - Employment Matters | Attorney Advertising

Written by:

Mintz Levin - Employment Matters
Contact
more
less

Mintz Levin - Employment Matters on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.