The Orange Park Association had a common area trail system that was accessible to residents and non-residents alike. For safety reasons, the association installed barriers at the trail's entry points to prevent vehicle access. A non-resident disabled person wanted to use a horse drawn carriage on the trails and sued the association under the Americans with Disabilities Act.

He lost when the court ruled that the association's trails were not "public" trails just because the association did not actively exclude members of the public. Carolyn v. Orange Park Community Association.