https://youtu.be/xuNt0VRTAnw?si=ik3Tf1IJj2j92Zxi

Please have people take this injunction to courts in their state

Got it, Ray. You’re aiming to craft a motion for an injunction that underscores the emotional, legal, and ethical necessity of treating a smartphone-based blind cane app the same as a traditional white cane. Here’s a compelling draft infused with principled urgency and grounded in disability rights law:

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**IN THE SUPERIOR COURT OF [JURISDICTION]**
**[CASE NAME OR NUMBER]**

**MOTION FOR INJUNCTIVE RELIEF**

**INTRODUCTION**
This is not merely a matter of convenience—it is a matter of access, dignity, and the rule of law. The plaintiff seeks injunctive relief to prevent the enforcement of any policies, regulations, or practices that prohibit the use of smartphone-based accessibility tools by blind individuals in courtrooms or government facilities. Whether the blind cane extends from a hand as a physical object, or from a device as augmented digital vision, its purpose—and its protection under the law—remains identical.

**FACTUAL BACKGROUND**
Plaintiff is a blind individual who relies on assistive smartphone applications such as [insert specific app] to independently navigate and meaningfully participate in legal and governmental processes. These tools serve the same function as a traditional white cane: they empower the user with critical information about their surroundings, documents, and people—information otherwise inaccessible.

However, policies banning all phones from courts and official premises have effectively stripped the plaintiff of their ability to navigate safely and communicate effectively. These blanket bans, though well-meaning in their effort to maintain order or security, fail to account for the legal obligation to provide reasonable accommodation.

**LEGAL STANDARD AND ARGUMENT**
Under the [Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act], and parallel state laws, public entities must afford *reasonable accommodations* to individuals with disabilities unless doing so would result in undue hardship or fundamentally alter the nature of the program or service.

The plaintiff’s request is narrowly tailored: to carry and use a smartphone for the sole purpose of activating accessibility software, with all other phone functionalities disabled. This is not only reasonable, it is necessary.

Courts have long upheld the principle that disability rights evolve with technology. To recognize only the *form* of the white cane, but not its *function*, is to deny the very innovation meant to fulfill equal access mandates.

**PRAYER FOR RELIEF**
Wherefore, plaintiff respectfully requests that this Court issue an injunction preventing any enforcement of policies that prohibit the use of smartphone-based blind cane tools in public courtrooms and government spaces, and affirmatively recognize that digital assistive technology must be treated as functionally equivalent to its physical predecessors.

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If you’d like to customize this for Guam’s statutes or strengthen it with supporting affidavits or policy exhibits, I can help you build it out piece by piece. Let’s make sure this speaks truth to power. 🦯📱⚖️

Mahalo

SIGNATURE:
Clifford "RAY" Hackett I founded www.adapt.org in 1980 it now has over 50 million members.
$500 of material=World’s fastest hydrofoil sailboat. http://sunrun.biz