Notice of Population-Level ADA Communication Risk – Brighton
On June 17, 2026, Transparent Law Enforcement issued formal notice to the Town of Brighton and the Brighton Police Department regarding population-level ADA Title II communication risk.
The notice concerns structural operational-verification risk regarding interpreter access for Deaf and hard-of-hearing individuals during law enforcement encounters. It is not based on a single incident, officer, or complainant.
Sent to:
William Moehle, Town Supervisor
David Catholdi, Chief of Police
Copied to:
Daniel Aman, Brighton Town Clerk
Councilmember Nathaniel V. Salzman, Public Safety Committee Chairperson
Councilmember Christine E. Corrado, Community Services Committee Chairperson
Monroe County Deaf Equity Council
Disability Rights New York
Notice Text
Supervisor Moehle and Chief Catholdi,
This correspondence serves as formal notice of population-level ADA Title II communication risk within the Town of Brighton and the Brighton Police Department.
This notice is based on records produced through the Freedom of Information Law, including Brighton Police Department Policy 331, Brighton Police Department Procedure 331, interpreter vendor materials, disability-awareness training materials, the Town ADA policy and grievance procedure, and related FOIL correspondence.
This notice is not incident-based. It concerns structural operational-verification risk regarding interpreter access for Deaf and hard-of-hearing individuals during law enforcement encounters.
I. FOIL-Documented Record Posture
The Brighton Police Department maintains a written policy and procedure governing communication with persons with disabilities, including individuals who are Deaf or hard of hearing.
Those materials establish a comparatively developed interpreter-access framework. The record includes a written police policy, a related procedure manual, interpreter access pathways, LanguageLine phone and video interpreting materials, onsite interpreting materials, a Tellmorr ASL services agreement, disability-awareness training materials, public communication materials, and a Town ADA policy and grievance procedure.
The issue identified through this review is not the absence of written materials. The issue is that the records produced do not establish that the written interpreter-access framework is operationalized, measured, or reviewed in actual police encounters.
Under Title II of the Americans with Disabilities Act, public entities must furnish appropriate auxiliary aids and services where necessary to afford effective communication, and must give primary consideration to the individual’s expressed choice of aid or service. 28 C.F.R. § 35.160(b)(1), (b)(2).
Brighton’s own policy and procedure create measurable operational requirements. They include identification of an individual’s preferred auxiliary aid or service in non-emergency situations, timing standards for qualified interpreter requests and availability, documentation requirements for communication assistance and interpreter use, documentation when an individual’s preferred communication method is not honored, and training and refresher training requirements for members who may have contact with individuals with disabilities.
The records produced do not establish interpreter usage data, interpreter response-time tracking, field use of video remote interpreting, actual use of ASL interpreter vendors in police encounters, report documentation of auxiliary aids or communication preferences, training rosters or refresher records, supervisory review of interpreter-access decisions, or device readiness and patrol access to video interpreting.
The produced record therefore documents a written interpreter-access framework, but does not establish an auditable operational system.
II. Population-Level Risk Implications
The concern identified here is structural and population-level because it is not tied to one incident, one officer, or one complainant.
It concerns whether Deaf or hard-of-hearing individuals who encounter the Brighton Police Department can rely on the written interpreter-access framework being available, used, documented, and reviewed in practice.
Policy 331 and Procedure 331 recognize that effective communication may require qualified interpreters, video remote interpreting, written exchange, or other auxiliary aids depending on the nature, length, complexity, and context of the encounter. Those materials also recognize that simple communication methods may not provide effective communication in all circumstances.
Without operational records showing when interpreter services are requested, when they are provided, how long they take, how communication preferences are documented, and when alternative methods are used, the records produced do not demonstrate that the Department’s written effective-communication framework is functioning in the field.
This creates structural risk during encounters involving rights advisements, custodial communication, interviews, consent, medical or safety information, accident investigations, enforcement action, or other circumstances where communication must be accurate, timely, and documented.
III. Governance and Oversight Risk
The Town identified the Director of Personnel as the Town ADA Coordinator and produced a Town ADA policy and grievance procedure.
That response identifies a Town-level ADA Coordinator. It does not fully resolve the police-specific governance question raised by Brighton Police Department Policy 331.
Policy 331 states that the Chief of Police shall delegate certain responsibilities to an ADA coordinator. It further states that the coordinator shall be appointed by and directly responsible to the Staff Services Captain. The policy assigns that coordinator operational duties, including maintaining a list of qualified interpreter services, developing procedures for accessing auxiliary aids and qualified interpreters, ensuring those procedures are available to members, acting as liaison with disability groups, and ensuring appropriate processes exist for complaints and inquiries regarding access to department services.
The policy also states that this police-related coordinator works with the Town ADA Coordinator.
The records produced do not clearly identify the police-specific coordinator contemplated by Policy 331, explain whether the Human Resources Director also holds that police-policy role, or show how the Town ADA Coordinator is integrated into police operations.
That unresolved governance structure matters because the policy assigns implementation duties to that role. Those duties directly relate to interpreter pathway maintenance, member access to procedures, liaison work, complaint routing, and operational review.
IV. Notice Function
This correspondence documents that the absence of operational-verification records for Brighton’s interpreter-access framework has been identified through the FOIL process.
The Town of Brighton and the Brighton Police Department are now on notice of the structural exposure created by the current record posture.
Transparent Law Enforcement will preserve this correspondence as part of the Monroe County Interpreter Access Audit record.
No specific action is requested in this correspondence.
The purpose of this notice is documentation of risk and preservation of the administrative record.
Respectfully,
Cadhla McBride
Transparent Law Enforcement
admin@transparentlawenforcement.com
This notice has been provided for documentation and public record purposes. Any clarification or additional materials provided by the Town/Village will be reflected in future updates.