L.K. v. The Renfrew Center of Massachusetts, LLC.

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUETTS
CIVIL ACTION No. 25-cv-12819-RGS
L.K., by her parents MARISA HOWARD-KARP
and ISADORA HOWARD-KARP
v.
THE RENFREW CENTER OF MASSACHUSETS, LLC
MEMORANDUM AND ORDER
ON DEFENDANT’S MOTION TO DISMISS
January 12, 2026
STEARNS, D.J.
This suit is brought by Marisa Howard-Karp (Marisa) and Isadora
Howard-Karp on behalf of their daughter, plaintiff L.K., a seventeen-year-
old who is deaf and has dysgraphia, a learning disability that affects “her
ability to process and produce written text.” Compl. [Dkt #1] ¶¶ 1, 10. L.K.’s
parents allege that The Renfrew Center of Massachusetts, LLC (The Renfrew
Center), which offers treatment to individuals with eating disorders, refused
to offer reasonable accommodations to L.K. in violation of the Americans
with Disabilities Act (ADA), 42 U.S.C. §§ 12182, et seq. (Count I); the
Massachusetts Public Accommodation Law, Mass. Gen. Laws ch. 272, § 98
(Count II); and the Massachusetts Equal Rights Act, Mass. Gen. Laws ch. 93,
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§ 103 (Count IV).1 Compl. ¶¶ 73-74, 80, 88.2 The Renfrew Center moves to
dismiss the Complaint for failure to state a claim under Fed. R. Civ. P.
12(b)(6). For the following reasons, the court denies the motion to dismiss.
BACKGROUND
The following facts are drawn from the Complaint and viewed in the
light most favorable to L.K. as the nonmoving party. In 2024, L.K.
1 The ADA prohibits discrimination against any person because of
disability and imposes a positive obligation on an ADA defendant to provide
a plaintiff with reasonable accommodations. Soileau v. Guilford of Maine,
Inc., 105 F.3d 12, 15 (1st Cir. 1997). Under the ADA, unlawful discrimination
includes providing an “unequal” benefit to disabled individuals or providing
such individuals a benefit that is “different or separate from that provided to
other individuals, unless such action is necessary to provide” a benefit “that
is as effective as that provided to others.” 42 U.S.C. § 12182.
Massachusetts law likewise forbids discrimination because of a
disability. The Massachusetts Public Accommodation Law prohibits
“distinction, discrimination or restriction on account of . . . deafness,
blindness or any physical or mental disability . . . relative to the admission of
any person to, or his treatment in any place of public accommodation.”
Mass. Gen. Laws ch. 272, § 98. Similarly, the Massachusetts Equal Rights
Act requires that “person[s] within the commonwealth, regardless of
handicap . . . shall, with reasonable accommodation, have the same rights as
other persons . . . to the full and equal benefit of all laws and proceedings for
the security of persons and property, including . . . the rights secured under
Article CXIV of the Amendments to the Constitution.” Mass. Gen. Laws ch.
93, § 103.
2 The Complaint also included an additional Count III, alleging that
The Renfrew Center violated Article 114 of the Amendments to the
Massachusetts Constitution, which L.K.’s parents subsequently agreed to
dismiss. Pl.’s Opp’n to Def.’s Mot. to Dismiss. [Dkt #14] at 1.
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participated in two programs at The Renfrew Center: a partial
hospitalization program from January through March and an outpatient
program from March through April.3 Id. ¶¶ 14, 16. Both programs consisted
of individual, family, and group therapy, all of which took place in person.4
Id. ¶¶ 15, 17, 24. The Renfrew Center provided L.K. with an ASL interpreter
for all programming during this time. Id. ¶ 24.
In December of 2024, Marisa emailed The Renfrew Center, requesting
that it evaluate L.K. for additional treatment. Id. ¶ 27. In its response, The
Renfrew Center outlined the accommodations that it would offer to L.K. if
she were to return to the outpatient program.5 Id. ¶ 29. The proposed
accommodations would include an in-person ASL interpreter for L.K. during
individual sessions but not group sessions. Id. Instead, the Center proposed
that L.K. participate remotely in group sessions using a Video Remote
3 The Renfrew Center’s partial hospitalization program takes place on
five days a week for six hours each day, while its outpatient program takes
place on three days a week for three hours each day. Id. ¶¶ 15, 17.
4 The Renfrew Center’s group sessions include both therapy and
communal meals: “[P]atients eat and interact together with a therapist
present to support them,” and they “receive support and detailed nutritional
education through oral communication from treating professionals.” Id. ¶
20.
5 This correspondence took place between Marisa and Christen
Murray, a member of The Renfrew Center’s residential admissions team. Id.
¶¶ 27, 29.
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Interpretation (VRI) service, an online platform on which an offsite
interpreter would use a camera or videophone to provide ASL interpretation
to L.K. Id. ¶¶ 35-36. Marisa, together with L.K.’s social worker and a referral
specialist from the Massachusetts Commission for the Deaf, corresponded
with The Renfrew Center in the weeks that followed6 explaining their view
that L.K.’s needs could only be met with in-person ASL translation.7 Id. ¶¶
39-40, 47.
In February of 2025, The Renfrew Center revised the proposed
accommodations with respect to group sessions, substituting the VRI
accommodation with an automated virtual platform. Id. ¶¶ 48-49. The
substitution would still require L.K. to participate in group sessions
remotely, using a platform that would provide closed captioning as well as a
digital chat function for communicating with the group. Id. ¶ 50. The Center
cited the costs of VRI as the reason for the substitution. Id. ¶ 55.
6 This correspondence included emails from The Renfrew Center’s
assistant vice president, Jillian Hartman, and its vice president of outpatient
operations, Lori Ciotti. Id. ¶¶ 35, 41.
7 In January of 2025, The Renfrew Center evaluated L.K. for eating
disorder treatment and recommended that she “receive nine hours per week
of treatment, comprised of two hours of individual therapy and seven hours
of group therapy sessions” for a period lasting between two and four months.
Id. ¶¶ 45-46. The evaluation was conducted using an ASL interpreter. Id. ¶
45.
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L.K.’s parents contend that this new accommodation would not
provide L.K. with equal access to the outpatient program. Id. ¶ 51. As stated
in the Complaint:
Captioning cannot interpret or voice L.K.’s statements in ASL for
the other participants in the virtual therapy sessions. Reliance
on automatic captioning would require L.K. to quickly read and
process everything said by members of the group on the caption
panel and also type everything that she wanted to say in the
online chat function, posing significant challenges due to her
Dysgraphia. With automatic captioning and chats as her only
means of communicating, L.K. would not be able to equally
participate in or benefit from the content the treatment
professional provides or conversations with fellow participants.
L.K. could not join in and respond in a timely manner, isolating
and disconnecting her from her peers, and decreasing her
chances of success in the program.
Id. ¶¶ 52-53.
The Complaint alleges that, in refusing to provide an ASL interpreter
for group sessions, The Renfrew Center violated the ADA, the Massachusetts
Public Accommodation Law, and the Massachusetts Equal Rights Act. Id. ¶¶
73-74, 80, 88. L.K.’s parents seek various forms of relief: a court declaration
that The Renfrew Center has violated the ADA and state law, an injunction
against any continuing discriminatory conduct, compensatory and punitive
damages, and reasonable attorney’s fees and costs. In its motion to dismiss,
The Renfrew Center argues (in vague terms) that “plaintiff’s allegations rest
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solely on subjective characterizations and conclusory descriptions of alleged
general scenarios.” Mem. in Supp. of Mot. to Dismiss [Dkt # 12] at 4.
DISCUSSION
To survive a motion to dismiss under Rule 12(b)(6), a complaint “must
contain sufficient factual matter, accepted as true, to ‘state a claim to relief
that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009),
quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). Two basic
principles guide the court’s analysis. “First, the tenet that a court must
accept as true all of the allegations contained in a complaint is inapplicable
to legal conclusions.” Iqbal, 556 U.S. at 678. “Second, only a complaint that
states a plausible claim for relief survives a motion to dismiss.” Id. at 679. A
claim is facially plausible if its factual content “allows the court to draw the
reasonable inference that the defendant is liable for the misconduct alleged.”
Id. at 678. If the allegations in the complaint are “too meager, vague, or
conclusory to remove the possibility of relief from the realm of mere
conjecture,” the complaint will be dismissed. SEC v. Tambone, 597 F.3d 436,
442 (1st Cir. 2010) (en banc).
Whether The Renfrew Center’s proposed accommodations of L.K.’s
disability were reasonable is a determination of fact that cannot be resolved
on the barebones of the pleadings before the court. The burden of showing
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that a requested accommodation is reasonable rests with the plaintiff in an
ADA suit. See Mulloy v. Acushnet Co., 460 F.3d 141, 147 (1st Cir. 2006).
Under the circumstances of the case, it is difficult to see how L.K.’s parents
could meet that burden without the benefit of discovery and, most likely,
expert testimony on whether The Renfrew Center’s proposals are sufficiently
tailored to L.K.’s needs and satisfy the ADA’s reasonableness requirement.
In L.K.’s case, this issue can only be addressed in the context of a summary
judgement motion, or if necessary, at a trial. See Delgado-Echevarria v.
AstraZeneca Pharm. LP, 856 F.3d 119, 128 (1st Cir. 2017) (a plaintiff must
show at the summary judgment stage, that a requested accommodation
under the ADA is facially reasonable; where plaintiff fails to show such
reasonableness, summary judgment for the defendant is appropriate).8
ORDER
For the forgoing reasons, The Renfrew Center’s motion to dismiss is
DENIED.
SO ORDERED.
/s/ Richard G. Stearns
UNITED STATES DISTRICT JUDGE
8 Whether a defendant’s counteroffer of an accommodation was
equally reasonable under the circumstances would obviously figure in a
factfinder’s assessment of whether a plaintiff had met her preponderance of
the evidence burden on this issue.
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