The FCC lists fines for E911 compliance violations, but civil lawsuits can prove far more financially devastating.
How much do you think an E911 compliance violation could cost your organization? $500? $5,000? $50,000? Try $40 million – or more. While the FCC outlines fines for E911 violations, the true cost of noncompliance is potential tragedy and a wrongful death judgment that could easily put most companies out of business. Yet many organizations – including businesses, hospitals, schools, municipalities, and event venues – unknowingly fail to comply with Kari’s Law and RAY BAUM’s Act, the federal regulations that govern E911 for multi-line telephone systems (MLTS). Moreover, some schools are noncompliant with Alyssa’s Law, a relatively new statute adopted by six U.S. states. Here, we offer an overview of the E911 laws and the true cost of noncompliance, plus explain how to ensure your organization is compliant to prevent devastating outcomes.Summary
E911 violations can carry fines of up to $10,000 plus $500 per day, per device
Wrongful death lawsuits are costlier. Jurors in one case awarded a family more than $40 million. Another case was settled for $8 million
Organizations must prioritize compliance with Kari’s Law, RAY BAUM’s Act, and Alyssa’s Law (for schools) to prevent tragedy, reputational damage, expensive fines, and devastating lawsuits
Kari’s Law and RAY BAUM’s Act
The FCC has two major E911 mandates for organizations with multi-line telephone systems: Kari’s Law and RAY BAUM’s Act.Kari’s Law
The law was named after Kari Hunt, who was murdered by her estranged husband in a Texas hotel room in 2013. Kari’s nine-year-old daughter attempted multiple 911 calls but couldn’t get through because she didn’t know the phone system required an access code to reach an outbound line. Kari’s Law states that multi-line telephone systems must:Support direct dialing 911 (no access codes such as “9”)
Notify a central on-site location OR an off-site location where someone is likely to see it
Relay a callback number
Relay caller location information
RAY BAUM’s Act
RAY BAUM’s Act mandates that all phones send accurate, dispatchable location information to Public Safety Answering Points (PSAPs), including enhanced location identifiers such as building, floor, wing, and room number. Penalties for Kari’s Law and/or RAY BAUM’s Act Noncompliance FCC Fines The Code of Federal Regulations outlines fines of up to $10,000 plus $500 per day, per device, for violating Kari’s Law and/or RAY BAUM’s Act. However, those fines aren’t fixed, and actual penalties could vary on a case-by-case basis.Civil Lawsuits
More severe penalties can come in the form of civil lawsuits. In 2018, a jury awarded Kari Hunt’s family $41.55 million in a wrongful death suit that claimed the hotel was negligent for delaying emergency response. It’s important to understand that this was before the E911 laws were enacted, which means the hotel was technically compliant with existing laws and a jury still found it liable. Now, with E911 laws in effect, it’s not difficult to imagine a jury awarding a greater sum if an organization were found noncompliant.In July 2022, a six-year-old boy drowned in a pool at a St. Louis County, Missouri summer camp. The county had recently upgraded its phones, but E911 wasn’t provisioned correctly, and the 911 call was routed to a special call center in Colorado, delaying emergency response. The boy’s family filed a $40 million wrongful death suit against the county, and the suit was settled for $8 million in July 2023.
These cases underscore the fact that FCC penalties, while significant, pale in comparison to the financial impact of a wrongful death suit for E911 noncompliance.
Alyssa’s Law
Though it’s not a federal regulation (yet), Alyssa’s Law has been passed in six U.S. states:
New Jersey
Florida
New York
Texas
Tennessee
Utah
Legislation has also been introduced in multiple federal bills and ten additional states:
Nebraska
Arizona
Virginia
Oregon
Georgia
Michigan
Massachusetts
Pennsylvania
Oklahoma
Alabama
The exact requirements vary by state, but generally mandate that schools incorporate or consider incorporating the following:
Silent panic buttons installed in K-12 schools
Panic buttons must instantly notify PSAPs and on-site personnel (such as school administrators and resource officers)
In some states, silent panic buttons must be mobile (worn by teachers and staff)
Penalties for Alyssa’s Law Noncompliance
Like the regulations, penalties vary by state, but could include:
Loss of state funding: For example, New Jersey schools must comply with Alyssa’s Law to be eligible for security grants
State intervention: States could require schools to develop compliance plans or subject them to additional oversight
In addition to state-issued penalties, precedents set by E911 wrongful death cases suggest that school districts could face similar lawsuits if noncompliance delayed response during an emergency event.
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