Passage of “Kari's Law” Imposes New 9-1-1 Obligations on Hotels
By Michael Pryor Shareholder, Brownstein Hyatt Farber Schreck LLP | April 22, 2018
On Dec. 1, 2013, Kari Hunt Dunn was stabbed repeatedly by her estranged husband in a hotel room in Marshall, Texas. Her children were also in the room. Kari's then 9-year-old daughter tried to call 9-1-1 four times from the hotel room phone but never got through because she didn't know that she had to dial 9 first to get an outside line. Kari did not survive the attack. This horrible story ignited action by legislators around the country, pushed by Kari's family and, in particular, the tireless efforts of her father, Hank Hunt, to ensure that callers could reach 9-1-1 from hotel phones without having to dial extra digits.
Those of us who work in offices or large organizations are familiar with telephone systems that allow us to reach co-workers, even in different states, by dialing just a few numbers-like 5555. These systems are called multi-line telephone systems or MLTS, which are used in hotels and business offices. To reach an outside line on one of these systems, however, we know to dial a prefix, usually 9, and then dial the number we want to reach. Kari's daughter did not know she had to do this to reach emergency services.
To avoid similar tragedies, states and local governments were the first to begin adopting what has become known as Kari's Laws. Texas adopted the initial Kari's Law in 2015, quickly followed by Maryland, Tennessee and Oklahoma. Other states and local governments have followed suit. Typically, these state and local laws require hotels and businesses to ensure that employees and guests can reach emergency services by dialing 9-1-1 without having to dial additional numbers. Some laws impose further obligations on MLTS, such as passing information that allows emergency call centers to obtain the caller's address. These laws typically require companies to come into compliance by a certain date, perhaps with some exceptions or a longer grace period for older, hard to modify systems.
Efforts were also being made at the federal level. Bills were first introduced in Congress in 2015. On Jan. 23, 2017, a bill, sponsored by Rep. Louie Gohmert, who represents Mr. Hunt's district, passed the House of Representatives by a vote of 408-0. The Senate subsequently passed its version of Kari's Law, also unanimously, on Aug. 3, 2017. House and Senate conferees ironed out slight differences in their respective bills and President Trump signed the law on Feb. 16, 2018, which also happened to be the 50th anniversary of the first 9-1-1 call in Haleyville, Ala.
Then Commissioner and now Federal Communications Commission Chairman Ajit Pai personally took up the cause as well. Shortly after hearing about the tragic circumstances in Texas, then Commissioner Pai met with Mr. Hunt. Moved by his story, Mr. Pai then launched an inquiry into the 9-1-1 dialing capabilities of MLTS systems used in hotels and offices. Working with the lodging industry and MLTS manufacturers, the FCC quickly determined that the 9-1-1 dialing problem was widespread. According to a survey conducted by the American Hotel & Lodging Association early in 2014, direct dialing 9-1-1 did not work in over 55 percent of franchised hotels and in 68 percent of independent hotels. Mr. Pai also learned that most of the MLTS manufacturers did not ship their products with a default setting allowing direct 9-1-1 dialing.
In fact, Mr. Pai discovered that the FCC's office building did not permit direct 9-1-1 dialing, much to his chagrin.
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