Narrative Opinion Summary
In this case, the plaintiffs, represented by Thomas Stoutenborough and Self-Help for Hearing Impaired Persons, filed a class-action lawsuit against the National Football League (NFL) and several broadcasters, challenging the NFL's 'blackout rule' under the Americans With Disabilities Act (ADA) and other federal statutes. The 'blackout rule' restricts local broadcasts of home games that are not sold out 72 hours before kickoff, which the plaintiffs allege discriminates against hearing-impaired individuals by limiting their access to televised games. The district court dismissed the lawsuit, finding that the plaintiffs did not state a viable claim under the ADA. The appellate court affirmed this decision, noting that the 'blackout rule' applies equally to all individuals, regardless of hearing ability, and that hearing-impaired individuals have access to radio broadcasts through technological advancements. The court also determined that the statutes cited by the plaintiffs, including Titles I, II, and III of the ADA, do not apply to the NFL or its media partners as they are not public accommodations under the law. Additionally, Title IV of the ADA and the Communications Act of 1934 were found irrelevant to the claims. Ultimately, the court concluded that the 'blackout rule' does not violate any protected rights, and the dismissal of the case was upheld.
Legal Issues Addressed
Americans With Disabilities Act Title IIIsubscribe to see similar legal issues
Application: The court determined that Title III of the ADA does not apply because televised broadcasts are not considered services of public accommodation.
Reasoning: The district court noted that the statute addresses practices of public accommodations that deny access to their services, but since none of the defendants qualify as a public accommodation under the defined categories, they are not subject to Title III's provisions.
Application of Titles I and II of the ADAsubscribe to see similar legal issues
Application: Titles I and II were found inapplicable as they cover employment discrimination and public entities, neither of which are relevant to the case.
Reasoning: Titles I and II of the Americans With Disabilities Act (ADA) are deemed inapplicable to the case at hand.
Communications Act of 1934subscribe to see similar legal issues
Application: The Act does not extend ADA protections to the 'blackout rule' and does not create a private cause of action.
Reasoning: The Communications Act of 1934 does not indicate any congressional intent to extend the ADA's protections to the 'blackout rule.'
Definition of Public Accommodation under ADAsubscribe to see similar legal issues
Application: The court concluded that the NFL and its media partners do not qualify as public accommodations under Title III of the ADA.
Reasoning: The regulations clarify that a 'place' must be a facility affecting commerce within those categories, which does not include the NFL or its media partners.
Federal Rule of Civil Procedure 12(b)(6)subscribe to see similar legal issues
Application: The court granted the motion to dismiss under Rule 12(b)(6), as the plaintiffs failed to state a claim upon which relief could be granted.
Reasoning: The court accepted the complaint's allegations as true for the purpose of a 12(b)(6) motion to dismiss, but determined that the law does not support a violation of a protected right based on the facts presented.
Title IV of the ADA and the Television Decoder Circuitry Actsubscribe to see similar legal issues
Application: Title IV does not apply as it concerns telephone services and specific closed captioning, which are irrelevant to the NFL's 'blackout rule.'
Reasoning: However, the term 'common carriers' as defined in Title IV does not encompass television broadcasters.