Nathanson v. Spring Lake Park Panther Youth Football Ass'n
2015 WL 5286770, 129 F.Supp.3d 743, 2015 U.S. Dist. LEXIS 120530 (2015)
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Rule of Law:
A private entity, such as a youth sports association, that does not own a physical space but 'operates' a place of public accommodation by controlling and using it for its primary activities is subject to the anti-discrimination provisions of Title III of the Americans with Disabilities Act (ADA).
Facts:
- David and Gloria Nathanson and their two sons, D.N. and G.N., are all deaf and primarily communicate using American Sign Language (ASL).
- The boys previously played for a different athletic association that provided and paid for ASL interpreters and used a sideline drum to signal the start of plays.
- In 2014, the Spring Lake Park Panther Youth Football Association (the 'Football Association') was formed to organize youth football in the area.
- After the local school district ceased providing interpreters for the non-school-sponsored activity, the Nathansons requested that the Football Association provide ASL interpreters for their sons' games and practices, but the requests were denied.
- The Football Association also discontinued the use of the sideline drum.
- David Nathanson, an experienced coach, applied for a coaching position but was not offered one; the Football Association also refused to provide him an ASL interpreter for a mandatory coaches meeting.
- The Football Association failed to provide interpreters for David and Gloria Nathanson at other mandatory events, including a parent meeting and a 'Tackle Football Mom's Clinic'.
Procedural Posture:
- David Nathanson, Gloria Nathanson, and their two children sued the Spring Lake Park Panther Youth Football Association and four of its officers in the United States District Court for the District of Minnesota.
- Plaintiffs alleged violations of Title III of the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA).
- Following settlement discussions, the claims against the individual officer defendants were voluntarily dismissed.
- The remaining defendant, the Football Association, filed a Motion to Dismiss for failure to state a claim.
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Issue:
Does a youth sports association that does not own but regularly uses and controls public football fields for its games and practices qualify as a 'place of public accommodation' under Title III of the Americans with Disabilities Act (ADA)?
Opinions:
Majority - Montgomery, District Judge.
Yes, a youth sports association can qualify as a 'place of public accommodation' under the ADA if it operates the physical location where its services are provided. Title III of the ADA applies not just to entities that own or lease property, but also to those who 'operate' a place of public accommodation. Citing the Supreme Court's decision in PGA Tour, Inc. v. Martin, the court reasoned that an organization can be an operator if it controls the use of a physical space for its events. Here, the plaintiffs plausibly alleged that the Football Association 'operates' the football fields by scheduling games and practices, which suggests it has an arrangement allowing it access and control. This level of control distinguishes the Football Association from a membership organization that merely 'visits' or 'patronizes' a public accommodation without the authority to make changes. Therefore, at the motion to dismiss stage, the plaintiffs have stated a valid claim that the Football Association is subject to the ADA.
Analysis:
This decision clarifies that the definition of 'place of public accommodation' under the ADA is not strictly limited to entities with a direct ownership or leasehold interest in a physical property. It extends ADA obligations to membership organizations, such as sports leagues, that exercise sufficient control over public or private facilities to be deemed an 'operator.' This broad interpretation ensures that entities cannot evade anti-discrimination laws simply by using, rather than owning, the spaces where they offer their services. Future litigation will likely focus on the factual question of what degree of control over a space is sufficient to qualify an organization as an 'operator' for ADA purposes.
