A. L. v. Walt Disney Parks and Resorts US, Inc., No. 20-12720 (11th Cir. 2022)
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A.L. is an adult male diagnosed with autism. A.L. is in his late twenties, but his developmental age is “five-to-seven years old.” A.L.’s case is one of over forty actions filed by plaintiffs with disabilities against Disney in Florida and California federal courts, asserting that Disney failed to accommodate their requested modifications to its disability-accommodation program in violation of 42 U.S.C. Section 12182(b)(2)(A)(ii). The district court entered final judgment in favor of Disney after determining that A.L.’s requested modification to receive either ten “Re-admission Passes” for each person in his party or unlimited access to Disney’s expedited “FastPass” lines for its theme park attractions was neither necessary to accommodate A.L.’s disability nor reasonable under the Americans with Disabilities Act of 1990 (the “ADA”).
The Eleventh Circuit affirmed. The court wrote it discerned no clear error in the district court’s factual findings, no legal error in its fundamental-alteration analysis, and no abuse of discretion in its evidentiary rulings. Moreover, the district court here applied the correct legal test. It considered whether the requested modification would affect merely peripheral aspects of Disney’s parks or aspects essential to Disney’s services. The court further found that the other reasons A.L. offers for the presentation of the excluded evidence are neither relevant nor probative of the individualized injunctive relief he sought.
This opinion or order relates to an opinion or order originally issued on August 17, 2018.
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