Carparts Distribution Center v. Automotive Wholesalers Association of New England

Citation
Carparts Distribution Center v. Automotive Wholesalers Association of New England Inc., 37 F.3d 12 (1st Cir. 1994) (full-text).

Appellate Court Proceedings
The court held that the term "public accommodations," as used in the Americans with Disabilities Act of 1990 was not limited to actual physical structures. The court reasoned that

"[b]y including "travel service" among the list of services considered "public accommodations," Congress clearly contemplated that "service establishments" include providers of services which do not require a person to physically enter an actual physical structure. Many travel services conduct business by telephone or correspondence without requiring their customers to enter an office in order to obtain their services. Likewise, one can easily imagine the existence of other service establishments conducting business by mail and phone without providing facilities for their customers to enter in order to utilize their services. It would be irrational to conclude that persons who enter an office to purchase services are protected by the ADA, but persons who purchase the same services over the telephone or by mail are not. Congress could not have intended such an absurd result."

The First Circuit concluded that "to exclude this broad category of businesses from the reach of Title III and limit the application of Title III to physical structures which persons must enter to obtain goods and services would run afoul of the purposes of the ADA." }}