One Man Has Filed 1,800 Disability Lawsuits Against SoCal Shops.
A Democratic Assemblyman Just Killed the Bill That Would Have Stopped It.
Anthony Bouyer, 55, is paralyzed from a 1991 car accident. He is also an internet marketer who, according to court records and investigative reporting by the Los Angeles Times and RealClearInvestigations, has filed approximately 1,885 disability-access lawsuits against Southern California small businesses — ranging from family restaurants to corner liquor stores. His lawsuits do not seek ramps, accessible bathrooms, or sign changes. They seek cash — typically $14,000 in settlement demands per case — exploiting a California statute that turns federal ADA technical violations into mandatory $4,000 cash payouts with no pre-suit notice required.
Bouyer is not alone. Seven serial filers together filed more than 1,000 ADA lawsuits in Southern California in 2025 alone, all clients of Manning Law APC — a firm whose founder, Joseph R. Manning Jr., was suspended by the California State Bar on November 6, 2025 for fabricating billing statements in an unrelated matter. California filed 8,667 ADA Title III lawsuits in 2025 — more than any other state for the second straight year, accounting for 37% of all such litigation in the United States. Los Angeles County has been named the No. 1 Judicial Hellhole in America by the American Tort Reform Foundation for 2025-2026.
A bipartisan fix passed the California Senate 34-2. Then it hit one committee. Then Assemblyman Ash Kalra (D-San Jose), chair of the Assembly Judiciary Committee, declined to give it a hearing — killing the bill without a vote. Small business owners who paid $14,000 to settle rather than spend $50,000 to $100,000 fighting in court are still waiting for Sacramento to act.
- 1,885Lawsuits filed by Anthony Bouyer aloneAnthony Bouyer, 55, Rancho Dominguez — paralyzed 1991, self-described 'disability advocate.' Court records and LA Times / RealClearInvestigations reporting document approximately 1,885 ADA filings against Southern California small businesses.
- 1,000+Additional ADA suits by 6 other Manning firm clients — 2025 aloneSeven serial filers collectively filed over 1,000 ADA lawsuits in Southern California in 2025. All were clients of Manning Law APC. Manning founder Joseph R. Manning Jr. was suspended by the CA Bar on November 6, 2025 for fabricating billing statements.
- $14,000Average settlement demand per caseTypical settlement range: $10,000–$16,000. The math: California Unruh Act mandates $4,000 per violation. Plaintiffs stack multiple violations per visit. Fighting and winning costs $50,000–$100,000 in defense attorneys' fees. Most owners settle. The fee-shifting trap is structural.
- 8,667ADA lawsuits filed in California in 2025Most ADA Title III lawsuits of any state for the second consecutive year. California accounts for 37% of all U.S. ADA Title III litigation. 92% of all California accessibility claims are filed by only 5 law firms. Source: Institute for Legal Reform.
- 34-2CA Senate vote for SB 84 reform — then one Democrat blocked itSB 84 (Sen. Roger Niello, R-Fair Oaks; co-authored by Sen. Angelique Ashby, D-Sacramento) passed the California Senate 34-2. Assembly Judiciary Committee Chair Ash Kalra (D-San Jose) refused to schedule a hearing, killing the bill in committee without a vote.
- #1Los Angeles — Judicial Hellhole of the Year 2025-2026American Tort Reform Foundation ranked Los Angeles County the top Judicial Hellhole in America for 2025-2026, citing serial ADA litigation, mass tort abuse, and California's plaintiff-friendly Unruh Act as primary drivers.
- 1-yearCA Bar active suspension — Manning Law founderCalifornia State Bar imposed a 1-year active suspension on Joseph R. Manning Jr. effective November 6, 2025 for fabricating billing statements in attorney fee declarations — conduct the Bar described as dishonesty involving moral turpitude. Manning is the founding attorney of Manning Law APC, the firm representing Bouyer and six other serial filers.
Federal ADA Title III requires public accommodations — restaurants, stores, hotels — to provide accessible facilities. The federal remedy is injunctive relief only: fix the problem, no cash damages. Congress designed it that way intentionally, to encourage compliance over extraction.
California’s Unruh Civil Rights Act (Civil Code §51) goes further — it attaches a mandatory $4,000 cash penalty per violation to any ADA barrier. Multiple violations in a single visit can stack. And California requires no pre-suit notice to the business owner: a plaintiff can file a lawsuit without ever giving the owner a chance to fix the problem first. Many other states and the federal system require a “cure period” — California does not.
California also applies fee-shifting: lose a case and pay the plaintiff’s attorneys’ fees. In practice, a small business facing a $14,000 settlement demand can either pay it — or spend $50,000 to $100,000 fighting in court, risking a larger judgment and an attorneys’ fee award on top if the judge sides with the plaintiff. The rational economic choice is almost always to settle.
1. No pre-suit notice required. California does not require plaintiffs to notify a business of an ADA violation before filing suit. The first contact is often a lawsuit complaint, not a letter. Many business owners learn they are being sued for a sign that was 1/8 inch too low or a parking space stripe that was 2 inches too short.
2. “Drive-by” standing.California courts have allowed standing based on a plaintiff visiting (or even photographing) a business from the parking lot and claiming the visible barrier “deterred” access. Some filers have claimed deterrence for violations documented without entering the business at all.
3. Mandatory $4,000 per violation — stackable. Each Unruh violation carries a mandatory $4,000 penalty. Multiple barriers (parking, entrance, interior, restroom, signage) can be cited in the same complaint, multiplying the exposure quickly. There is no cap on the number of violations per visit.
4. Fee-shifting trap.If the business contests and loses, it owes the plaintiff’s attorneys’ fees on top of the $4,000-per-violation award. Against a firm like Manning Law APC — which has filed thousands of identical complaints — the fee exposure to a small business defending one case can reach $50,000–$100,000. Settlement for $10,000–$16,000 is mathematically the cheaper option for almost every defendant.
Anthony Bouyer, 55, of Rancho Dominguez, has filed approximately 1,885 ADA lawsuits against Southern California businesses, according to court records reviewed by the Los Angeles Times and RealClearInvestigations. He was paralyzed in a 1991 car accident and describes himself as a “disability advocate.” He is also an internet marketer. His cases follow a consistent pattern: a brief visit (or documented approach) to a local small business, identification of an accessibility barrier, and a lawsuit seeking statutory damages under the Unruh Act.
Six other Manning Law APC clients collectively filed over 1,000 additional ADA lawsuits in Southern California in 2025, according to HotAir’s analysis of court filings. Together, seven individuals associated with a single suspended attorney’s firm filed more than 2,000 ADA lawsuits in one year in one region of one state.
Brian Whitaker is another Southern California serial filer — 1,700+ documented cases. In one federal proceeding, the judge found his testimony “not credible.” Scott Johnson of Carmichael, a Sacramento-based attorney who also operated as a serial ADA plaintiff, was sentenced to 18 months home detention in April 2023 for federal tax fraud — charges stemming partly from undisclosed income from his ADA litigation settlements. The California State Bar has identified the pattern; the Legislature has failed to act.
“This person is just suing anyone. It's just for nitpicking things.”
Steven Barraza, family restaurant owner — on Anthony Bouyer's lawsuit against his business
“This money's for my kids, not for him.”
Zuheir Nakkoud, Sylmar liquor store owner — after paying $14,000 to settle Bouyer's lawsuit
Senate Bill 84 was introduced by Sen. Roger Niello (R-Fair Oaks) with a Democratic co-author, Sen. Angelique Ashby (D-Sacramento). The bill would have required pre-suit notice to businesses before an ADA lawsuit could be filed — a standard reform already adopted in Florida, Texas, and other states — giving owners 90 days to cure documented accessibility barriers before being dragged into court.
The California Senate passed it 34-2. That is a supermajority margin, with substantial Democratic support. The bill moved to the Assembly.
It was referred to the Assembly Judiciary Committee, chaired by Assemblyman Ash Kalra (D-San Jose). Kalra declined to schedule the bill for a hearing. Under California Assembly rules, a bill that does not receive a hearing in committee dies. SB 84 died. No vote. No debate. No testimony from shop owners. No public hearing. One elected Democrat, in one chairmanship, exercised veto power over a reform passed by more than 90% of the California Senate.
Assemblyman Ash Kalra (D-San Jose)— Chair, California Assembly Judiciary Committee. Represents Assembly District 27 (San Jose). First elected 2016. Former Santa Clara County Superior Court attorney. Member of the Assembly’s progressive caucus. The Assembly Judiciary Committee under Kalra’s chairmanship has a documented pattern of refusing to hear tort reform legislation.
Kalra has not issued a public statement explaining why SB 84 was denied a hearing. The California Trial Lawyers Association — the state’s most powerful plaintiff’s bar lobbying group — is among the largest contributors to California Assembly Democrats. The NFIB California chapter called the outcome “a shakedown protected by Sacramento.”
Sen. Roger Niello (R-Fair Oaks), the bill’s Republican primary author, documented the stakes bluntly: “A single plaintiff has filed 47 lawsuits against Sacramento businesses in three years.” His bill was bipartisan, narrowly tailored, and nearly unanimous in the Senate. It still could not get a hearing in one Democratic-controlled committee.
Joseph R. Manning Jr. founded Manning Law APC, the firm that handled the bulk of Anthony Bouyer’s 1,885 lawsuits and represented the other six serial filers. Manning Law developed an assembly-line approach to ADA litigation: identify serial plaintiffs, coordinate visits to local businesses, document barriers, and file near-identical complaints in volume.
On November 6, 2025, the California State Bar imposed a 1-year active suspension on Manning for fabricating billing statements submitted to courts in attorney fee declarations. The Bar’s public order described the conduct as involving “moral turpitude” — the professional standard for dishonesty that goes beyond negligence. Manning’s suspension was imposed in a matter unrelated to the ADA litigation volume itself, but it was the firm’s billing conduct under oath that triggered State Bar action.
The San Francisco and Los Angeles District Attorneys filed a civil lawsuit against Potter Handy LLP, a separate ADA litigation mill, accusing it of a similar shakedown operation targeting small businesses — an unusual DA-level intervention that signals how flagrant the pattern has become. That prosecution, however, did not result in legislation that would close the underlying statutory loophole.
Meet Anthony Bouyer, the man who has filed 1,800 disability lawsuits against SoCal shops. Small business owners say they're being shaken down. A bipartisan CA Senate bill to stop it passed 34-2 — then one Democratic assemblyman killed it in committee without a hearing.
At the federal level, President Trump’s Justice Department withdrew 11 pieces of ADA compliance guidance in early 2025, citing the cost burden they imposed on small businesses. A separate Presidential Memorandum directed the Attorney General to prioritize sanctioning attorneys and law firms filing frivolous federal lawsuits — a document that ADA reform advocates cited as signaling executive-branch concern about abuse of the statute.
Federal changes, however, do not reach the California Unruh Act — a state statute that independently authorizes the $4,000-per-violation cash damages unavailable under federal ADA Title III alone. The California legislature is the only body that can close the loophole. The California legislature, as of May 2026, has not done so.
Frivolous lawsuits are a DISASTER for American small businesses. My Justice Department will sanction lawyers who abuse the courts. We will not allow the legal system to be used as a shakedown machine against hardworking business owners.
Paraphrased commentary · not a verbatim post
Paraphrase of Trump's documented public position on frivolous lawsuit abuse. Primary source: Presidential Memorandum authorizing AG to sanction firms filing frivolous lawsuits; Trump DOJ withdrawal of 11 ADA compliance guidance documents (January–February 2025).
The arithmetic is brutal and the victims are not corporations. They are family restaurants, corner stores, and independent shops — the kind of small businesses the California Democratic Party claims to protect. Every settlement dollar paid to a serial ADA filer is a dollar that did not pay an employee, cover rent, or fund the actual accessibility improvements the ADA was designed to require.
Zuheir Nakkoud, owner of a Sylmar liquor store, paid $14,000 to settle one of Bouyer’s lawsuits. His response, on the record: “This money’s for my kids, not for him.” He was not given notice of any violation before the lawsuit arrived. He could not afford to fight.
Steven Barraza, a family restaurant owner sued by Bouyer, described the lawsuit as targeting “nitpicking things” unrelated to meaningful accessibility. “This person is just suing anyone,” he said. His business was not cited for blocking a wheelchair ramp. The violations documented were technical measurements — the kind that a 90-day cure period would have allowed him to fix for less than a few hundred dollars.
Neither owner has received any meaningful accessibility improvement from the settlement. The ADA’s original purpose — expanded physical access for people with disabilities — is not what these cases produce. They produce cash for plaintiffs and fees for suspended attorneys, and they leave the underlying barriers untouched because settlement agreements do not require remediation.
California has built a legal structure that turns federal disability law — designed to expand access — into a cash machine for serial plaintiffs and contingency-fee attorneys. One man has filed nearly 1,900 lawsuits. His attorney was suspended for fabricating billing records. Six other clients of the same firm filed 1,000 more lawsuits in a single year. California files 37% of all U.S. ADA litigation from 5% of the nation’s population.
The California Senate passed a bipartisan fix by 34-2. Then Ash Kalra (D-San Jose) killed it in committee without a hearing. The California Trial Lawyers Association — which contributes heavily to California Assembly Democrats — opposes pre-suit notice requirements. The small business owners of Sylmar and Hermosa Beach and San Jose paid $14,000 each so that this system could continue.
Presumption of innocence applies to all defendants in pending matters. Anthony Bouyer has not been charged with a crime. The conduct documented here — filing 1,885 lawsuits, accepting settlements, and targeting small businesses without pre-suit notice — is legal under current California law. That is the problem.

