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lawsuitappealsummary judgmentcorporationregulationappellant
appealsummary judgmentcorporationregulationappellant

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Miller v. California Speedway Corp., 536 F.3d 1020, 20 A.D. Cases 1508, 37 NDLR P 162, 08 Cal. Daily Op. Serv. 10,335, 2008 Daily Journal D.A.R. 12,366

Facts

Robert Miller, a quadriplegic who uses an electric wheelchair, brought a lawsuit against California Speedway Corporation under the Americans with Disabilities Act (ADA). He claimed that the wheelchair seating at the California Speedway did not provide him with a comparable line of sight to that of standing spectators during NASCAR events. The district court granted summary judgment in favor of the Speedway, concluding that the Department of Justice (DOJ) regulation did not require lines of sight over standing spectators. Miller appealed the decision.

Appellant Robert Miller is a big fan of NASCAR, attending from three to six events a year at the California Speedway in Fontana. He also happens to be a quadriplegic who uses an electric wheelchair. When the fans immediately in front of Miller stand during the most exciting parts of the race, they block his view of the action.

Issue

Does the Department of Justice's regulation requiring wheelchair areas in public accommodations to provide lines of sight comparable to those of the general public include a requirement for lines of sight over standing spectators?

Does the Department of Justice's regulation requiring wheelchair areas in public accommodations to provide lines of sight comparable to those of the general public include a requirement for lines of sight over standing spectators?

Rule

The Department of Justice's interpretation of its own regulations is entitled to substantial deference unless it is plainly erroneous or inconsistent with the regulation. The regulation mandates that wheelchair areas in public accommodations provide users with lines of sight comparable to those of the general public, which includes the necessity for wheelchair users to see over standing spectators in assembly areas where standing is expected.

The Department of Justice's interpretation of its own regulations is entitled to substantial deference unless it is plainly erroneous or inconsistent with the regulation. The regulation mandates that wheelchair areas in public accommodations provide users with lines of sight comparable to those of the general public, which includes the necessity for wheelchair users to see over standing spectators in assembly areas where standing is expected.

Analysis

The court analyzed the DOJ's interpretation of the regulation, determining that it was reasonable to require lines of sight over standing spectators, especially in the context of sporting events where audiences frequently stand. The court noted that the DOJ's interpretation aligns with the purpose of the ADA, which is to ensure accessibility for individuals with disabilities. The ambiguity in the regulation allowed for this broader interpretation, which the court found to be valid and deserving of deference.

The court analyzed the DOJ's interpretation of the regulation, determining that it was reasonable to require lines of sight over standing spectators, especially in the context of sporting events where audiences frequently stand. The court noted that the DOJ's interpretation aligns with the purpose of the ADA, which is to ensure accessibility for individuals with disabilities. The ambiguity in the regulation allowed for this broader interpretation, which the court found to be valid and deserving of deference.

Conclusion

The Court of Appeals reversed the district court's decision, holding that the DOJ's interpretation requiring lines of sight over standing spectators was reasonable and entitled to deference.

The Court of Appeals reversed the district court's decision, holding that the DOJ's interpretation requiring lines of sight over standing spectators was reasonable and entitled to deference.

Who won?

The Court of Appeals ruled in favor of Robert Miller, the appellant, reversing the district court's grant of summary judgment to California Speedway Corporation. The court found that the DOJ's interpretation of the ADA regulations was reasonable and required that wheelchair users have lines of sight comparable to those of standing spectators. This decision emphasized the importance of accessibility in public accommodations, particularly in settings where standing spectators could obstruct the view of individuals with disabilities.

The Court of Appeals ruled in favor of Robert Miller, the appellant, reversing the district court's grant of summary judgment to California Speedway Corporation. The court found that the DOJ's interpretation of the ADA regulations was reasonable and required that wheelchair users have lines of sight comparable to those of standing spectators. This decision emphasized the importance of accessibility in public accommodations, particularly in settings where standing spectators could obstruct the view of individuals with disabilities.

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