Who told you this? If it's your lawyer, listen to your lawyer. If it's the village idiot, you get what you pay for.
If you want somebody to brief this issue for you, I suggest hiring a law firm to do so.
It's quite a lot to ask us to do for free.
Joseph S. v. Hogan, 561 F. Supp. 2d 280 (E.D.N.Y. 2008).
Grammer v. John J. Kane Regional Centers-Glen Hazel, 570 F. 3d 520 (3d Cir. 2009).
42 U.S.C. § 1983.

