Notice of Population-Level ADA Communication Risk – Sheriff's Office
On September 12th, 2026, Transparent Law Enforcement issued formal notice to Monroe County and the Monroe County Sheriff's Office 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:
County Executive Bello
Sheriff Baxter
Copied to:
Monroe County Deaf Equity Council
Disability Rights New York
Notice Text
County Executive Bello and Sheriff Baxter,
Transparent Law Enforcement gives notice of a population-level ADA Title II communication risk concerning interpreter access for Deaf and hard-of-hearing individuals during Monroe County Sheriff's Office law-enforcement encounters. The concern is not incident-based and does not arise from any single deputy, encounter, or complainant. It is the produced record does not establish whether MCSO's documented interpreter-access framework is used, measured, and reviewed in practice.
This notice rests on records produced under the Freedom of Information Law, including MCSO General Order MBGO-093-16, current interpreter-service agreements, a Police Bureau interpreter-access bulletin, disability-awareness training materials, and the County's August 11 combined response to FOIL Requests 26-1840 and 26-1946. It reflects records reviewed through September 12, 2026. Additional records may change the findings below.
The documented framework
MCSO maintains one of the more developed written Deaf and hard-of-hearing communication frameworks reviewed in the Monroe County Interpreter Access Audit. MBGO-093-16 establishes procedures for communication with Deaf and hard-of-hearing victims, witnesses, suspects, arrestees, and other members of the public, addressing an individual's preferred communication method, qualified interpreters, written communication, video remote interpreting, TTY/TDD access, limits on reliance on family members, and documentation requirements.
The external infrastructure is documented as well. An agreement with Communication Services, Inc., doing business as Interpretek, provides certified sign-language interpreting for criminal investigations and other Sheriff's Office activities. An agreement with Tellmorr International Translation Services provides 24-hour on-demand in-person interpretation, expressly including American Sign Language, and requires an in-person interpreter to respond within four hours. A Police Bureau bulletin directs personnel to consider an over-the-phone service before contacting Tellmorr for in-person interpretation and to notify a command officer where possible.
This notice concerns the use of that framework.
The corresponding operational records were not produced or identified
MBGO-093-16 directs personnel to document interpreter-identifying information and the times an interpreter was called, arrived, and departed, and to preserve written communication exchanged with Deaf and hard-of-hearing individuals. The Tellmorr agreement separately requires the contractor to maintain records identifying the person requesting service, the date and time of the request, the date and time service was provided, the language involved, the interpreter used, and the associated cost, and to furnish those records to MCSO on request.
Together those provisions define an operational record trail when the system is used. No corresponding operational records were produced or identified.
The four-hour contractual standard therefore cannot be evaluated. MCSO policy and the Tellmorr agreement together generate the timestamps needed to measure response performance, and nothing in the record establishes that those timestamps are aggregated, monitored, or reviewed.
The training record has the same gap. The County produced substantial Deaf and hard-of-hearing curriculum but no records establishing which current MCSO deputies completed it, when, or whether it has been refreshed.
MCSO's own policy recognizes that communication needs vary with the nature and complexity of an encounter, and that written communication sufficient for a brief exchange may be insufficient for interviews, rights advisements, consent, accident investigation, medical or safety communication, custodial communication, or enforcement activity. The record does not show whether the framework is activated in those encounters.
County-level oversight
MBGO-093-16 provides that each bureau will have designated personnel acting as liaison between the bureau and Staff Services. The records reviewed do not identify the person currently serving in that role for the Police Bureau, or establish how that role connects to Monroe County's central ADA and language-access compliance function.
FOIL Request 26-1840 was directed to that central layer. It sought the central compliance function's own records: any MCSO-specific language-access plan; records identifying an MCSO language-access liaison, ADA contact, or comparable official; monitoring, assessment, deficiency, corrective-action, and follow-up records; aggregate records reflecting interpreter-service use; and complaint-tracking records.
The County's combined response produced MCSO policies, contracts, bulletins, and training materials. It did not produce records responsive to those central categories. It closed the requests as approved "as to existing records" without a category-by-category certification identifying which offices, custodians, or record systems were searched where responsive central records were not located.
The record therefore does not establish that central oversight of MCSO language access is absent. It establishes that such oversight is not documented in the records produced.
This notice places Monroe County and the Monroe County Sheriff's Office on notice that the produced record does not establish whether MCSO's interpreter-access framework is used, measured, and reviewed in practice. No action is requested. Transparent Law Enforcement will preserve this correspondence as part of the Monroe County Interpreter Access Audit record and will revise its findings if additional responsive records are produced.
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 County will be reflected in future updates.
This notice is part of the Monroe County Interpreter Access Audit (MCIAA), an ongoing Transparent Law Enforcement project examining how local agencies document interpreter access for Deaf or hard-of-hearing motorists.