Issues listed in the original lawsuit included: the GLO has no ownership rights to the property; false representation of data to obtain a federal U.S. Army Corps of Engineers permit to close the Pass; violations of the U.S. Constitution; violations of Environmental Policy, Clean Water and Rehabilitation Act requirements; failure by the USACE to analyze impacts of actions by those closing the Pass; failure to perform analyses of alternatives in the best interest of the public and socioeconomic impact; Rehabilitation Act discrimination against mobility impaired persons by not providing any alternate accessible place; discrimination against disabled persons in violation of the Americans with Disabilities Act; failure to consider and incorporate changes from Texas' recent judicial decision regarding public vs. private beaches; failure to address alternate structures such as jetties or groins to control sediment; and declaratory relief or injunction to prevent closure of Rollover Pass by the GLO