Pinnock v. International House of Pancakes

Theodore Pinnock (plaintiff) was an attorney who used a wheelchair for mobility. Pinnock visited an International House of Pancakes franchise owned by Majid Zahedi (defendants) and attempted to use the restroom facilities. However, the restroom entrance was not wide enough for Pinnock’s wheelchair. Pinnock lifted himself out of his chair and crawled into the restroom. Pinnock then filed suit against Zahedi in federal district court, alleging several state-law causes of action, as well as several violations of Title III of the Americans with Disabilities Act (ADA). Zahedi counterclaimed and filed for summary judgment, arguing that Title III of the ADA violated several provisions of the United States Constitution. The United States intervened as a counterdefendant to uphold the ADA’s constitutionality and filed a cross-motion for summary judgment. The district court addressed Zahedi’s arguments as the first court to consider constitutional challenges to the ADA. In evaluating the arguments, the court found that (1) Congress’s commerce powers permitted Congress to enact Title III as regulation of interstate commerce, and Title III applied to franchises like Zahedi’s; (2) Title III was not improper retroactive legislation because businesses were given notice periods to comply with the ADA before their noncompliance constituted a violation; (3) requiring businesses to make property alterations did not constitute an unconstitutional taking without compensation; (4) Congress did not unconstitutionally delegate authority by allowing the attorney general to create ADA implementation regulations; and (5) Title III did not unconstitutionally intrude upon state sovereignty. The court then addressed whether Title III was unconstitutionally vague.