LOF both (1) detailed the United finding that two-thirds of the surveyed polling places States’ were inaccessible and (2) set forth the United conclusion that Harris voting States’ County’s program violated the ADA on a system-wide basis. After the United States issued that LOF, Harris County claimed in a response letter that it was taking corrective actions with respect to its voting program as a whole. The 2016 survey was only intended to verify whether system-wide issues had been fixed. The United States orally explained some of the issues uncovered in the 2016 survey to Harris County officials, but it was the large-scale 2013 survey results—as detailed exhaustively in the 2014 LOF—that demonstrated that Harris voting program County’s was inaccessible on a system-wide basis. The United States could have brought suit based on the 2013 survey and 2014 LOF alone; it cannot be that an additional survey, intended only to verify Harris representations about its program, undermined the United ability to bring County’s States’ suit. The United States Has Properly Alleged That Harris County Violated Title II Harris County argues that the to plead enough facts to state a claim for “Complaint fails relief that is plausible on its face against Harris MTD at 10. But the Complaint need County.” only provide Harris County with notice of what the . . . claim is and the grounds upon “fair which it 550 U.S. 544, 555 (2007) (internal quotation marks Bell Atl. Corp. v. Twombly, rests.” and citation omitted). Here, the allegations in the Complaint clearly give Harris County fair notice of the claim (that Harris County has violated Title II of the ADA) and the grounds upon which it rests (that two-thirds of the polling places surveyed were inaccessible to people with disabilities, for the reasons set forth in the Letter of Findings). Federal Rule of Civil Procedure 8(a)(2) requires only short and plain statement of the “a claim showing that the pleader is entitled to Although facts are not relief”). “[s]pecific
LOF both (1) detailed the United States’ finding that two-thirds of the surveyed polling places were inaccessible and (2) set forth the United States’ conclusion that Harris County’s voting program violated the ADA on a system-wide basis. After the United States issued that LOF, Harris County claimed in a response letter that it was taking corrective actions with respect to its voting program as a whole. The 2016 survey was only intended to verify whether system-wide issues had been fixed. The United States orally explained some of the issues uncovered in the 2016 survey to Harris County officials, but it was the large-scale 2013 survey results—as detailed exhaustively in the 2014 LOF—that demonstrated that Harris County’s voting program was inaccessible on a system-wide basis. The United States could have brought suit based on the 2013 survey and 2014 LOF alone; it cannot be that an additional survey, intended only to verify Harris County’s representations about its program, undermined the United States’ ability to bring suit. The United States Has Properly Alleged That Harris County Violated Title II Harris County argues that the “Complaint fails to plead enough facts to state a claim for relief that is plausible on its face against Harris County.” MTD at 10. But the Complaint need only provide Harris County with “fair notice of what the . . . claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (internal quotation marks and citation omitted). Here, the allegations in the Complaint clearly give Harris County fair notice of the claim (that Harris County has violated Title II of the ADA) and the grounds upon which it rests (that two-thirds of the polling places surveyed were inaccessible to people with disabilities, for the reasons set forth in the Letter of Findings). Federal Rule of Civil Procedure 8(a)(2) requires only “a short and plain statement of the claim showing that the pleader is entitled to relief”). Although “[s]pecific facts are not