Landis v. WashingtonvState Major League Baseball Stadium Public Facilities District, No. 19-36075 (9th Cir. 2021)
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Under the Americans with Disabilities Act, 42 U.S.C. 12182(a), the Department of Justice (DOJ) promulgated 1991Accessibility Guidelines requiring that in sports stadiums, “[w]heelchair areas shall be an integral part of any fixed seating plan and shall be provided so as to provide people with physical disabilities a choice of admission prices and lines of sight comparable to those for members of the general public.” A 1996 DOJ guidance document (Accessible Stadiums) provides: Wheelchair seating locations must provide lines of sight comparable to those provided to other spectators. In stadiums where spectators can be expected to stand during the show or event (for example, football, baseball, basketball games, or rock concerts), all or substantially all of the wheelchair seating locations must provide a line of sight over standing spectators."
Plaintiffs, baseball fans with ADA-qualifying disabilities, use wheelchairs for mobility. The Stadium, designed in 1996 and constructed in 1997-1999, has vertically stacked seating levels sloped toward the field. There is wheelchair-accessible seating on each level. The district court rejected Plaintiffs’ sightline claim and, regarding the Accessible Stadiums standard, concluded: [W]hen the Court reviews the illustrations considering what can be seen over the line representing the standing spectator’s shoulders, i.e., “over the shoulders and between the heads,” more of the field is visible from the accessible seat, making the views comparable." The Ninth Circuit vacated. The district court failed to explain how the Stadium satisfies all the Accessible Stadiums requirements.
Court Description: Americans with Disabilities Act The panel vacated the district court’s judgment, after a bench trial, in favor of defendants and remanded for further proceedings in an action under the Americans with Disabilities Act. Plaintiffs alleged that spectators using wheelchairs at T- Mobile Park in Seattle had inadequate sightlines under the ADA, as implemented by the Department of Justice’s 1996 Accessible Stadiums document. The panel assumed without deciding that the district court did not err in applying the Accessible Stadiums guidance interpreting § 4.33.3 of the 1991 Accessibility Guidelines adopted by the DOJ. The panel held, however, that the district court did not properly apply this standard because it analyzed only the requirement that a person using a wheelchair must be able to see the playing surface between the heads and over the shoulders of the persons standing in * Formerly known as Danielle J. Hunsaker. LANDIS V. WASH. STATE MLB STADIUM PUB. FACILITIES DIST. 3 the row immediately in front. The panel held that the district court erred by failing to analyze the additional requirement that a person using a wheelchair must be able to see the playing surface over the heads of the persons standing two rows in front. The panel addressed additional issues in a concurrently filed memorandum disposition. Concurring, Judge Bumatay wrote that the case should be remanded for different reasons. Judge Bumatay wrote that the district court erred in summarily applying Auer deference to the Accessible Stadiums document as a binding interpretation of a disability regulation when Accessible Stadiums is a guidance issued by a section within the DOJ’s Civil Rights Division that, by its own terms, “has no legally binding effect,” and does “not establish legally enforceable responsibilities.” On remand, Judge Bumatay would ask the district court to perform the requisite analysis under Kisor v. Wilkie, 139 S. Ct. 2400 (2019), before deferring to the Accessible Stadiums guidance.
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