Matheis v. CSL Plasma, Inc.

936 F.3d 171 (2019)

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Matheis v. CSL Plasma, Inc.

United States Court of Appeals for the Third Circuit
936 F.3d 171 (2019)

  • Written by Arlyn Katen, JD

Facts

George Matheis (plaintiff), a retired police officer diagnosed with post-traumatic stress disorder (PTSD), donated plasma to CSL Plasma, Inc. (CSL) (defendant) for extra income. After Matheis had safely donated plasma about 90 times over 11 months, CSL turned Matheis away because Matheis brought a service dog for emotional support. CSL’s manager prohibited Matheis from donating plasma again until Matheis could provide CSL with a healthcare-provider letter stating that Matheis could safely donate without a service dog. CSL claimed that it did not allow people with severe anxiety to donate plasma; CSL classified anxiety as severe if it was managed with multiple daily medications or a service animal. Matheis sued CSL in federal district court, arguing that CSL had violated the Americans with Disabilities Act (ADA) by failing to accommodate his PTSD. CSL moved for summary judgment, arguing that CSL was not a public accommodation that was subject to the ADA and that Matheis’s anxiety posed a direct threat to safety at CSL. CSL’s sole direct-threat evidence was its medical director’s assertion that donors with severe anxiety might fail to follow directions, disrupt the donation process, and put staff and other donors at risk of needle wounds or unsafe exposure to blood. The district court found that CSL was a public accommodation subject to the ADA but granted CSL’s summary-judgment motion because Matheis’s severe anxiety was a legitimate, nondiscriminatory reason for CSL to refuse to allow Matheis to donate plasma. Both parties appealed.

Rule of Law

Issue

Holding and Reasoning (Ambro, J.)

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