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Colorado Is Creating Guidelines To Help Make Excruciating Coronavirus Care Decisions

CCDC in the News

What if four patients in respiratory distress need a ventilator to keep them alive, but a hospital has just one available? Who makes that call? And how?

Public health and community leaders are contemplating excruciating dilemmas just like that before demanding for medical help in the coronavirus crisis peaks in coming weeks.

They’re updating protocols, called “crisis standards of care,” for the most urgent medical decision-making possible, guidelines to determine, as resources get scarce, who gets care and at what level and who does not.

Continue to the original article.



CCDC’s Civil Rights Legal Program has numerous and growing concerns regarding discrimination against people with disabilities as a direct result of decision-making by both private and public entities occurring during the pandemic. When a crisis hits, as we all know (or at least our community is now finding out) people with disabilities and our civil rights get kicked to the curb!

These bad actors jump at every opportunity to Take advantage of what they call our “special rights,” but now that dogged discrimination is multiplied exponentially in order to violate our rights every time the word “emergency” gets used. These evildoers and lawbreakers will do everything in their power to ignore us and act as though somehow emergencies affect the lives of everyone else except people with disabilities. We know just the opposite is true.

Although Governor Polis’ administration has continued working with CCDC in a collaborative fashion and actively seeks input from CCDC regarding the needs of the disability community (something sorely lacking with respect to our needs and rights at other levels of government), the Civil Rights Legal Program stands ready to address to the best of our ability any form of discrimination against any individual or group on the basis of disability as a result of decision-making by governmental entities or private entities (such as the police, transportation providers, government entities failing to provide effective communication, doctors’ offices treating you differently based on disability, etc.) that occur related to the pandemic. All of us at CCDC, who have been working tirelessly to do our best to help our community in this time of crisis see COVID-19: RESOURCES, LINKS, AND INFORMATION FOR PEOPLE WITH AND WITHOUT DISABILITIES, recognize that almost everyone has been hit very hard by current circumstances, but that does not permit discrimination against people with disabilities to be allowed to go unchecked. We will not do so! Now, more than ever, our civil rights must and will be enforced!

As we all know, we always face the same problems as everyone else plus all of the problems related to our disabilities, most of which would be alleviated if people would simply do what they are supposed to under civil rights laws, but during this unprecedented and unimaginable crisis, we are really feeling the devastation far more so than our nondisabled counterparts. So many of us are just trying to figure out how to get out of bed in the morning given that we or maybe our attendants, our families, our friends, and our colleagues are falling victim to this foe that does not discriminate. Nevertheless, we are the most resilient, most resourceful and most likely to figure out the path to victory because that is what we have to do every day of our lives. For all of those reasons, we are here to help the best of our ability and in close connection with our allies in the field and other civil rights lawyers who are working harder than we’ve ever worked in our lives to make sure everyone – and I mean EVERYONE – receives the fair and equal treatment we and those who came before us have fought so hard for all of our lives.

Please go to our Intake Form for information about the types of cases we take. You can also contact our Legal Program Assistant, Kara Gillon, at or (303) 660-8254 if you feel you have been discriminated against on the basis of disability based on the above types of circumstances or any other disability-rights violation. Please remember that we only take cases involving civil rights discrimination on the basis of disability. Other problems should be handled by CCDC’s other non-attorney advocates who can be found on our website,

Obviously, we cannot guarantee that we can help in every circumstance; nor can we guarantee a perfectly successful outcome, but we have been here for you for 22 (almost 23) years doing all that we can with our small but, in my humble opinion, mighty staff taking on hundreds and hundreds of cases usually with good outcomes for the disability community in most circumstances (not always, but most). This is true even in the face of many more and more opponents who seem more defiant than ever to refuse to treat people with disabilities with humanity and equality as required on the law.

Those who would deny us our civil rights were growing in number and in willful disobedience of the law before, but this behavior is only been enhanced by the current pandemic. They never stop to think that we are the one minority group that they could join and, in the face of the current pandemic, just might join at any given moment. They need us not only to fight for ourselves but for them as well. Everyone is really just one sneeze away from the potential of needing those ventilators we keep hearing about and reading about in the news and perhaps requiring home healthcare for the rest of our lives. Oddly, many of us have lived under the circumstances for most of our lives. We truly are all in this together! But even that doesn’t stop them from discriminating and denying us equal opportunity under the law.

We must show those who will try to take advantage of a crisis to discriminate against us on the basis of our disabilities that we will not permit it! Although disability rights laws are not boundless (they do have their limitations), we are seeing firsthand and hearing about so many clear-cut violations of the law (and so many violations committed in the name of “emergencies” that we must remind those who will find any excuse to take advantage of us or the pandemic, our civil rights matter more now than ever!.

 -- Kevin Williams, CCDC Civil Rights Legal Program Director
and a member of the disability community for 33 -- almost 34 -- years and counting).

Letter to the Governor, RE: Survival of People with Disabilities during COVID-19 Pandemic

Read our letter crafted by our Executive Director and several partner organizations to Governor Polis regarding the Survival of People with Disabilities during COVID-19 Pandemic.

Download the fully accessible PDF Version

Blue line with three diamond shapes in the middle

CCDC Logo blue and black with the letters CCDC and the words Colorado Cross-disability Coalition



1385 S. Colorado Blvd., #610-A
Denver, CO 80222

Julie Reiskin
Executive Director
720.961.4261 (Direct)
303.648.6262 (Fax)

March 25, 2020, via Electronic Mail

The Honorable Jared Polis
Colorado State Capitol
200 East Colfax Room 136
Denver, CO 80203

Re: Survival of People with Disabilities during COVID-19 Pandemic

Dear Governor Polis,

We want to start this letter by thanking you for your extraordinary leadership during this crisis. Unlike our peers in other states, we are being included in policy decisions and working closely with members of your team (like Elisabeth Arenales) and your cabinet (Kim Bimestefer, Michelle Barnes, Jill Hunsaker-Ryan, and others). We appreciate being involved and allowed to help your administration make the best possible decisions in a horrible situation.

People with disabilities and chronic health conditions are doubly vulnerable during the COVID-19 crisis: they are vulnerable to acquiring the virus and to suffering more severe effects, and they are vulnerable to healthcare discrimination that may deny them necessary care. As a result, Coloradans with disabilities and chronic health conditions are experiencing escalating fear and anxiety, on top of any physical effects of the viral illness. We need your continued leadership to communicate and ensure that Colorado will protect
the rights and access to care of disabled people of all ages.

Colorado has a strong and united disability community that includes ADAPT, Centers for Independent Living, Arc Chapters, Disability Law Colorado, numerous organizations representing specific disability groups such as the Colorado Metal Wellness Network, the National Federation of the Blind Colorado chapter, and the Colorado Commission for the Deaf, Hard of Hearing, and DeafBlind. The Colorado Cross-Disability Coalition (CCDC) is the largest statewide organization run by and for people with all types of disabilities and we are working to coordinate with this amazing community to help with ongoing information dissemination and input to your team on policy issues. We are lucky to have such a strong and united community. This letter is written on behalf of many of these organizations, we wanted to get it out quickly so did not put extended time into sign-ons, but please note the organizations signed on below.

CCDC and others thank you for the swift and decisive actions that you have taken to protect the people of Colorado from COVID-19, reduce community spread, and flatten the curve. Your leadership will protect people with disabilities and their families from the virus’s accelerating spread, including daily increases in the deaths. Our community now asks that you take the following actions to ensure that people with disabilities receive equitable and effective healthcare in Colorado which will, in turn, help maintain the health of all Coloradans.

Prevent and Prohibit Medical “Rationing” Based on Disability

The prospect of shortages of medical staff and equipment for treating those made severely ill by COVID-19 has triggered a discussion of “rationing” medical care.

While the coronavirus crisis poses serious challenges to our social and health care systems, federal laws including the ADA, Section 504, Section 1557 of the ACA, and the Colorado Anti-Discrimination Act (CADA) prohibit any “rationing” measures by public or private entities which discriminate on the basis of disability. Denying care to disabled individuals who are likely to benefit from care is unlawful.

Moreover, swift and efficient action now may prevent or ameliorate the need for untenable rationing decisions. There are additional reserves of ventilators and other medical equipment and supplies maintained by hospitals and the U.S. Department of Defense and the Centers for Disease Control and Prevention.¹ Colorado must follow its own policy statements to ensure that these stockpiles are allocated based on objective need – and distributed throughout the state of Colorado so that health care workers have them on-site.² If existing numbers are projected to be insufficient, Colorado must procure additional equipment and supplies.

People are looking for factual information, honestly, and assurances. As Governor, you are the best person to speak out about the state’s efforts to alleviate widespread fear and anxiety among vulnerable populations, including Coloradans with disabilities.

We further urge the Governor and state agencies to swiftly issue a directive to health plans and insurers, hospitals, and other medical providers on maintaining their obligations under state and federal disability nondiscrimination laws during the coronavirus crisis, including in the allocation of scarce medical resources. Such guidance should include the following basic principles:

  • The presence of a disability, including a significant disability, is not a
    permissible basis for denying people access to care or giving them a lower
    priority for care.
  • The fact that a disabled person may have a lower likelihood of survival is not a
    permissible basis for denying care or allocating the person a lower priority for
    care. If the person will benefit from care, then they are entitled to access care on an equal basis as others.
  • The fact that a person with a disability may require reasonable accommodations during treatment, or more intensive treatment, is not a permissible basis for denying care or allocating the person a lower priority for care.
  • All medical decisions about providing care must be based on current objective
    medical evidence, and not based on generalized assumptions about a person’s
    disability. Treatment decisions shall not be made based on misguided assumptions that people with disabilities experience a lower quality of life.

Covered entities should be permitted to prioritize those with a greater urgency of need, and delay non-urgent care. They need not allocate scarce resources to individuals with no reasonable chance of survival. But people with disabilities should not face discrimination in seeking life-sustaining care that they will benefit from. The lives of people with disabilities are equally valuable to those without disabilities, and healthcare decisions based on devaluing the lives of people with disabilities are discriminatory. Benefit should be derived solely based on medical evidence, not a belief about the life of the patient.

Ensure Access to Home-and Community-Based Services and Related Services

Individuals with various disabilities who rely on personal care assistance face a dilemma during the COVID-19 crisis. No person with a disability should have to choose between catching a potentially deadly new virus and receiving the assistance needed to perform critical activities of daily living such as toileting, eating, dressing, etc. Personal care assistants whether paid or unpaid, should not be required to perform their duties without proper protective equipment to ensure both their own well-being as well as the continued well-being of their own families and other clients with disabilities or face the ethical dilemma of rendering necessary duties while beginning to feel sick.

The following measures are needed to preserve the well-being of people with disabilities while they shelter in place:

  • Fund paid sick leave for any personal care worker unable to work regularly
    scheduled shifts because of illness or the need to quarantine due to exposure. This must also cover any Medicaid consumer-directed or private pay client. Grants to small home health agencies should be made available to allow them to pay their workers. Larger agencies should be required to do the same.
  • Fund and establish backup personal care assistant (PCA) registries, for both
    public and private pay PCAs, and establish streamlined on-call emergency backup alternatives to ensure PCA services when scheduled PCAs are unavailable.
  • Place a moratorium on Medicaid LTSS reassessments that could lead to service hour reductions and consider revising overtime rules.
  • Provide and efficiently distribute protective gear for paid and unpaid PCAs,
    including family, friends, and volunteers who are providing personal attendant
    services. To the extent that shortages make this impossible, provide funding
    for substitute items such as cleaning gloves, industrial respirators, scrubs,
    garbage bags, etc.
  • Continue to include disability-specific providers (whether formal or not, paid or
    not) within the guidance on categories of “essential business” and “essential personnel,” such as public and private personal care attendants, public transit and paratransit, privately contracted Non-Emergency Medical Transportation (NEMT) providers, durable medical equipment providers/repairers, and veterinarians.

Even short gaps in coverage of personal care attendants and related services can lead to worsened health and unnecessary hospitalization or institutionalization, contrary to the integration principles adopted by the U.S. Supreme Court in Olmstead v. L.C., 527 U.S. 581 (1999). These risks are sharply heightened by the dangers posed by the coronavirus.

CCDC and the signatories below urge the following additional steps to ensure that disabled Coloradans are safe in their homes and communities with supports during the COVID-19 crisis:

  • Ensure that accurate and up-to-date information about the progression of COVID-19 within Colorado is fully accessible in alternative print and online formats.
    • We appreciate seeing the sign language interpreters at all of your press conferences. Please make sure videos are always captioned properly (just turning on YouTube captioning does not work). We appreciate the remarkable responsiveness of your staff, especially the Lt. Governor’s Chief of Staff, Crestina Martinez, Maria De Cambra on your Communications team and Theresa Montano in OIT when there has been an error in document accessibility. We hope that process improvements to assure no document goes up that is not fully accessible to people that use screen reading technology are prioritized.
    • We also urge that essential documents are quickly translated into threshold languages, adapted for people with lower reading abilities, and made available in American Sign Language and captioned videos. This must apply not only to Executive Orders but to instructions that are important including how to apply for unemployment, testing protocols, prevention protocols, etc.
  • Require all private insurers operating in Colorado to provide fully accessible, current, clear, and readily available information about in-network and out-of-network coverage of COVID-19 testing and treatment.
  • Require public utilities and internet providers to maintain gas, electricity, water, telephone, and internet services for seniors and people with disabilities sheltering in place.
  • Ensure that public and private insurance prioritization of healthcare procedures consider not only the category of procedure before canceling or delaying it as “elective/non-urgent,” but also the underlying conditions and cross-disability needs of the person who will be undergoing a scheduled procedure.
  • Continue provision of ADA paratransit, NEMT, and accessible on-demand service for passengers, including trips to the grocery store, medical facilities, and COVID-19 testing sites. Maintain ADA paratransit service areas even where bus routes are cut or reduced like areas such as Summit and Gunnison.
  • Protect passengers and workers by ensuring the provision of adequate protective gear and cleaning supplies for transit workers, including NEMT providers and janitorial support staff.
  • Place a comprehensive state-wide moratorium on evictions and a hold on termination of public benefits, including all administrative actions that result in individuals being cut off from public benefits. We also ask that any fraud investigations be suspended as this is not a good use of money or resources and could endanger the at-risk individuals.
Ensure Legal Services and Prompt Affirmative Responses to the Potential Violations of Rights of Disabled Coloradans.

We ask that Colorado take steps to bolster financial and human resources in Colorado’s legal service organizations to ensure that they have – the capacity to provide timely representation for individuals who face unlawful medical “rationing” based on disability, any unnecessary and involuntary institutionalization, evictions, benefits issues and other forms of discrimination in COVID-19 treatment and testing.

From past disasters, we know that legal services needs tend to peak 2-12 months after the disaster “ends”. Additional legal services support will be required for the next year. Specifically, Disability Law Colorado, Colorado Legal Services, Colorado CrossDisability Coalition, Civil Rights Education and Enforcement Center, and The Colorado Center for Law and Policy will need support to meet the legal needs of low-income Coloradans with Disabilities.

We further ask that you ensure that Colorado and its agencies respond immediately and effectively to any reports or complaints indicating that the rights of people with disabilities are being violated. While this must include prioritization and streamlining of administrative complaint procedures at all relevant agencies to respond affirmatively and forcefully to any formal or informal report.

Our state has long been a leader in many aspects of healthcare, accessibility, and civil rights protections for people with disabilities. Colorado, as the home of the Atlantis Community, the organization that created ADAPT is the birthplace of the internationally known disability rights movement. Help us to maintain our reputation as a leader in preserving the rights of people with disabilities. We would welcome the opportunity to continue to work with your administration on ensuring that people with disabilities in our state receive equal and effective healthcare during the COVID-19 crisis under the priorities detailed above.

Julie Reiskin, Executive Director, Colorado Cross-Disability Coalition

Ailsa Wonnacott, Association for Community Living, Boulder and Broomfield Counties

Martha Mason, Executive Director, Southwest Center for Independence

Wilfred Romero, The Arc – Pikes Peak Region

Darla Stuart, Executive Director, The Arc of Aurora

Larry McDermott,  The Arc of Weld County

Timothy Fox, Attorney at Law, Senior Partner, Civil Rights Education and Enforcement Center

Sara Froelich, Chronic Care Collaborative

Lisa Franklin, Executive Director, Parent to Parent

Candie Burnham, Executive Director, Atlantis Community, Inc.

Robert A. Lawhead, Colorado Developmental Disabilities Council

Christiano Sosa, Executive Director, The Arc of Colorado

Hope Hyatt, Colorado Mental Wellness Network

Christine Fallebell, The American Diabetes Association

Ian Engle, Executive Director, Northwest Colorado Center for Independence

Jessalyn Hampton, National MS Society

Judith I. Ham, Ability Connection Colorado

Eileen Doherty, Colorado Gerontological Society

Barbara Henry, Domino Service Dogs

Linda Skaflen, Executive Director, The Arc of Adams County

¹ Dan Lamothe, “Pentagon offers respirators, ventilators and labs in expanding coronavirus response,” Washington Post (Mar. 17, 2020) (describing the release of 5 million masks and 2,000 ventilators from military stockpile),;

² Surge Standards, Foundational Knowledge, § 8.4.3, Allocation of Ventilators for Pandemic Influenza, (“[T]he allocation of ventilators from State and federal stockpiles must take into account the ratio of local populations to available resources, designating appropriate resources for the most vulnerable who are most likely to suffer the greatest impact in any disaster.”).


Calming Ourselves & Building Our Power

From Julie Reiskin, Executive Director, Colorado Cross-Disability Coalition

To ensure better outcomes for our community during this unprecedented time, Colorado Cross-Disability Coalition is being proactive, compassionate, and conscious in our response to COVID-19.

Please review the following related to our business operations effective immediately and ways you can support our community:

  • Office Operations: CCDC staff will work remotely and will continue to be reachable through email and phone. Our office remains open, however, there will be very limited staff present during normal business hours. We do not encourage external visitors at this time. CCDC staff is prohibited from attending gatherings of 20 or more people. Additionally, internal and external meetings will be postponed or rescheduled as phone calls or via the online Zoom platform, when possible. All in-state and out-of-state business travel have been suspended.
  • Upcoming events: All community gatherings and events hosted by CCDC through April will be rescheduled for a later date, if possible. Any event already scheduled after May will remain scheduled at this point including our ADA 30th Anniversary Celebration in July. We will continually assess the situation and review recommendations from the Colorado Department of Public Health and Environment (CDPHE) and make changes as necessary.
  • How you can support: In this environment of social distancing closures and racist attacks, community needs are shifting by the hour. CCDC acknowledges many members of our community may not have access to food, basic needs, paid family leave, health care, child care, and other valuable resources. Our community regularly experiences social isolation as well. Therefore our community is more likely to be negatively impacted during a public health crisis. This is a time for kindness. Here is how you can help. We highly encourage our volunteers and donors to consider volunteering or making a donation to our direct impact community partners including Mile High United Way, Denver Homeless Out Loud, Asian Pacific Development Center and Colorado Immigrant Rights Coalition.
  • Resources from us to you: During any time of crisis, misinformation and rumors can cause fear and unnecessary anxiety. This resource page provides quick links and references to answer many of your questions and calm your concerns. This resource page will be updated every day so you can expect the most up to date information.
  • Government resources you can trust: While we are often the ones saying not to trust the government on some issues, in this particular subject, the government sites are the most accurate. Specifically:

NOTE: If you encounter inaccessible documents, videos without captions, no ASL interpreters, or any other form of disability discrimination in relation to COVID-19, please send us an email at We will take action if necessary.

If you have any other questions or concerns regarding CCDC’s response to COVID-19, email us at and a staff member will reply as quickly as possible.

Stay well and remember nothing about us, without us.
In solidarity,
Your Friends at CCDC

Nothing About Us Without Us…Ever!
CCDC is a member of

The Coronavirus & People with Disabilities

A Statement From the Colorado Cross-Disability Coalition

CCDC members have asked to hear from us about COVID 19 or the Coronavirus, and what it means for people with disabilities in Colorado. This memo will attempt to explain what we know to date. Please be assured that CCDC staff continue working (some from home and all of us safely), advocating, and ensuring the response efforts do not forget people with disabilities. We will also demand effective and accessible communication from all levels of government. If you encounter inaccessible documents, videos without captions, no ASL interpreters, or any other form of disability discrimination, please let us know immediately.  We created an email address for this purpose Continue reading “The Coronavirus & People with Disabilities”

Denver police officer blocks handicap spot at disability advocates’ HQ during emergency call

Police officials say vehicle wasn’t there long

By  | | The Denver Post PUBLISHED:  | UPDATED: 

A Denver police vehicle is seen partially in a handicap parking space at the headquarters for the Colorado Cross-Disability Coalition on Feb. 24.
A Denver police vehicle is seen partially in a handicap parking space at the headquarters for the Colorado Cross-Disability Coalition on Feb. 24.

A Denver police officer parked a marked patrol vehicle partially in a handicap spot at the headquarters for the Colorado Cross-Disability Coalition last month, blocking access to a van driven by the coalition’s legal director, who uses a wheelchair. Continue reading “Denver police officer blocks handicap spot at disability advocates’ HQ during emergency call”

Denver officer photographed blocking handicap spot at disability advocates’ headquarters

by: Evan Kruegel for KDVR Fox 31
Posted: Mar 5, 2020 / 10:12 PM MST / Updated: Mar 5, 2020 / 10:12 PM MST

See the original newscast/story


DENVER (KDVR) — The Denver Police Department has issued an apology after an officer was photographed parking in a handicap spot during an emergency call.

That handicap-accessible spot happened to be in front of the Colorado Cross-Disability Coalition, which specializes in advocating for those with disabilities.

A Denver police vehicle is seen partially in a handicap parking space at the headquarters for the Colorado Cross-Disability Coalition on Feb. 24.
A Denver police vehicle is seen partially in a handicap parking space at the headquarters for the Colorado Cross-Disability Coalition on Feb. 24.

Photos show the officer taking up a portion of the handicap spot as well as the majority of the “access aisle,” used by many at the building to get in and out of vehicles. Continue reading “Denver officer photographed blocking handicap spot at disability advocates’ headquarters”

Denver Police Park in place for the disabled at the headquarters of the disability advocacy group

By Matilda Coleman- March 6, 2020 for

Read the original article

A Denver police vehicle is seen partially in a handicap parking space at the headquarters for the Colorado Cross-Disability Coalition on Feb. 24.
A Denver police vehicle is seen partially in a handicap parking space at the headquarters for the Colorado Cross-Disability Coalition on Feb. 24.

A Denver police officer parked a partially marked patrol vehicle in a disabled place at the Colorado Disability Coalition headquarters last month, blocking access to a van driven by the coalition’s legal director, who uses a wheelchair.

Legal director Kevin Williams said Thursday that he wanted to draw attention to the incident because he routinely receives complaints about Denver police parking in places for disabled people. Continue reading “Denver Police Park in place for the disabled at the headquarters of the disability advocacy group”

Legislation geared toward people who register fake emotional support animals not likely to be introduced this year

Posted: 8:29 PM, Feb 27, 2020   Updated: 12:29 PM, Feb 28, 2020
By: Eric Ross

Read the original story here.

COLORADO — We’ve shown you the stories of people trying to pass off untrained pets as emotional support animals.

Disability advocates say as time goes on, the problem is getting worse.

State Rep. Larry Liston (R-Colorado Springs) drafted legislation as a result of a News 5 investigation we aired last Spring, but we discovered the bill is unlikely to be introduced this year. The goal of the bill would have defined the process of how people can obtain letters “certifying” their pet as an emotional support animal. Continue reading “Legislation geared toward people who register fake emotional support animals not likely to be introduced this year”

Behavioral Health Task Force Public Testimony at Division of Insurance on 3/6/20

The Division of Insurance (DOI) is pleased to host a public testimony opportunity in partnership with the Behavioral Health Task Force on Friday, March 6, 2020, from 2-5 PM. We invite Colorado community members, providers, caretakers, and advocates to share their stories about their experiences interacting with the behavioral health care system. We want to know what you love, what you hate, and/or what we need as a state to ensure every single person has the opportunity to be healthy and well. Your story does not need to be related to commercial insurance. Continue reading “Behavioral Health Task Force Public Testimony at Division of Insurance on 3/6/20”

Important Notice
CCDC’s employees and/or volunteers are NOT acting as your attorney. Responses you receive via electronic mail, phone, or in any other manner DO NOT create or constitute an attorney-client relationship between you and the Colorado Cross-Disability Coalition (CCDC), or any employee of, or other person associated with, CCDC. The only way an attorney-client relationship is established is if you have a signed retainer agreement with one of the CCDC Legal Program attorneys.

Information received from CCDC’s employees or volunteers, or from this site, should NOT be considered a substitute for the advice of a lawyer. DOES NOT provide any legal advice, and you should consult with your own lawyer for legal advice. This website is a general service that provides information over the internet. The information contained on this site is general information and should not be construed as legal advice to be applied to any specific factual situation.

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