This Court has long recognized that "to facilitate the
orderly and sympathetic administration of the disability
program[s] * * *, the Secretary and Congress have
established an unusually protective * * * process for the
review and adjudication of disputed [disability] claims."
Heckler v. Day , 467 U.S. 104 (1984); Bowen v. City of New
York , 476 U.S. 467 (1986). However, for the past fifteen
years, the County of Los Angeles ("County") has sent
armed police officers to search Social Security disability
applicants by entering their homes through deception or
coercion and thereafter issuing criminal search reports
accusing the applicants of fraud or malingering, resulting
in a summary denial of benefits and thus violating disability
applicants' Fourth and Fourteenth Amendments rights
and their rights under the Americans with Disabilities
Act (ADA) and the Rehabilitation Act (RA).

In order to vindicate the disability applicants' rights
and stop the ongoing violations, petitioner asks this Court
to resolve the following questions presented:

1. Did police officers who are employed by the Los
Angeles County District Attorney's Office in a cooperative
State and Federal anti-fraud program act under color of
federal law, and are they immune from suits for equitable
relief under 42 U.S.C. § 1983, when they forcibly searched
Anh Thai and other disability applicants in connection with
their applications for Social Security disability benefits?

2. Are searches like those performed by the County
joint federal-state criminal investigators against disability
applicants, in which criminal fraud investigators coerce
entry into disability applicants' homes to search through
their most intimate areas, and thereafter issue fraud
reports causing the applicants to be denied benefits,
a violation of the applicants' Fourth Amendment and
Fourteenth Amendment Due Process rights?

3. Are Social Security disability applicants such as
Anh Thai "qualified individuals with disabilities" who must
be provided with reasonable ADA Title II accommodations
during criminal police searches particularly when there
are no exigent circumstances and the disabilty applicants
are unarmed and nonviolent?

Did police officers employed by the Los Angeles County District Attorney's Office act under color of federal law and are they immune from suits for equitable relief when conducting forcible searches of disability applicants?