Blood Feud: Matheis and the Fight for Disability Rights

On August 30, 2019, the U.S. Court of Appeals for the Third Circuit in Matheis v. CSL Plasma, Inc. held that plasma donation centers are public accommodations under the Americans with Disabilities Act (ADA). In doing so, the court split from the Fifth Circuit Court of Appeals and joined the Tenth Circuit Court of Appeals in requiring plasma donation centers to reasonably accommodate their donors’ disabilities. This Comment argues that the Third Circuit was correct in holding that plasma donation centers are service establishments under Title III of the ADA as the text and legislative history indicate the statute’s broad scope. It further argues that reading a direction of compensation requirement into the definition of “service establishment” overlooks the complex nature of the American market system.