911 and Only 911

February 2020

As of February 16, 2020, new multi-line phone systems must allow direct dialing 911. In 2013, Kari Hunt Dunn died after her estranged husband entered her hotel room and stabbed her. Kari's nine-year-old daughter tried calling 911 four times on the hotel phone, but she was unable to reach anyone because she did not dial "9" before "911".

In response, Congress passed Kari’s Law Act of 2017 (“Kari’s Law”), which amends the Communications Act of 1934 as it applies to an MLTS (multi-line telephone system), defined as “a system comprised of common control units, telephone sets, control hardware and software and adjunct systems, including network and premises based systems.” This essentially encompasses the telephone systems used at most businesses. Kari's Law requires that MLTSs allow users to dial 911 without having to first dial an extra digit or other prefix. The MLTS must also provide a notification to a central location (e.g., the front desk of a hotel) at the facility where the MLTS is or to another person or organization regardless of location.

Kari’s Law applies broadly to any person that manufactures, imports, sells, leases, installs, manages, or operates MLTSs. In addition, based on guidance from the Federal Communications Commission (FCC), the law appears to apply not just to manufacturers of MLTS, but to the manufacturer’s customers. 

Pursuant to the closely related RAY BAUM’s Act of 2018, the MLTS must, when a 911 call is made, send a dispatchable location to the 911 operator. “Dispatchable location” is defined as “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party.” 

Kari’s Law applies only to an MLTS that is manufactured, imported, offered for first sale or lease, or first sold, leased, or installed after February 16, 2020. The FCC has advised that RAY BAUM’s Act has the same exceptions. MLTSs in service before this date are expressly grandfathered. However, if a business replaces or upgrades its MLTS, even if the MLTS was manufactured before February 16, 2020, the business may need to comply with Kari’s Law and RAY BAUM’s Act. In the meantime, the FCC advises that businesses should, as a voluntary best practice, inform users of their MLTS on how to accurately dial 911 without an extra digit or prefix. The FCC notes that many existing MLTSs already have these capabilities.

When the FCC asked for public comments on Kari’s Law, the feedback included inquiries about the costs of complying with the notification aspect of Kari’s Law. However, the FCC calmed these concerns, noting that the notification aspect of Kari’s Law applies only if the MLTS can “be configured to provide the notification without an improvement to the hardware or software of the system.” According to the FCC, businesses are not required to undertake “upgrades to the core systems of an MLTS, substantial upgrades to the software, or any software upgrades that require a significant purchase in order to comply with the notification obligation.”

Enforcement of Kari’s Law and RAY BAUM’s Act falls under the FCC’s jurisdiction, but Kari’s Law does not specify the range of fines or potential enforcement actions. The FCC acknowledges that enforcement will be on a case-by-case basis. Many businesses have recognized the importance of complying with Kari’s Law and RAY BAUM’s Act, and, if required to under those laws, are working to ensure that their MLTS products can direct dial 911, notify a central location when a user dials 911, and send a dispatchable location to the 911 operator. If you need assistance complying with Kari’s Law or RAY BAUM’s Act, please contact the authors of this alert.

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