In Wisconsin, Susan Bauer sued her local government after it demanded she mow her foot-high grass. Ms. Bauer claimed the Constitution gave her the right not to mow her grass. After that suit was rejected, Ms. Bauer filed another lawsuit under the Americans with Disabilities Act, claiming she suffered from chronic back problems, and demanding exemption from the ordinance, even though the town offered to cut her grass for free. That lawsuit was also rejected.

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