## Facts

- Lawrence O. Anderson, a wheelchair user due to a spinal cord injury, served for several years as an on-field Little League base coach without reported safety incidents.
- Little League Baseball, Inc. adopted a written policy barring coaches who use wheelchairs from the on-field coach’s box, allowing coaching only from the dugout, citing player safety and collision concerns.
- Local league officials did not enforce the policy during the regular season and allowed Anderson to continue coaching on the field.
- Despite opposition from various Little League officials, national leadership reaffirmed the policy and sought compliance by threatening revocation of local charters and tournament privileges.
- Anderson sued under Title III of the Americans with Disabilities Act (ADA) and sought declaratory and injunctive relief to prevent disability-based exclusion from on-field coaching during tournament play.
- The matter came before the district court on Anderson’s application for a temporary restraining order (TRO).

## Issues

1. Whether Little League and its programs are subject to ADA Title III as a place of public accommodation, such that disability-based exclusion from participation is prohibited.
2. Whether a categorical ban on wheelchair-using coaches can be justified under the ADA’s “direct threat” safety exception without an individualized, evidence-based risk assessment.
3. Whether the requirements for a TRO were met, including likelihood of success on the merits, irreparable harm, balance of hardships, and public interest.

## Decision

- The court granted the TRO.
- The court enjoined defendants from preventing Anderson from participating fully as an on-field coach during the tournament.
- The court also enjoined defendants from intimidating or threatening others (including local league officials) in connection with Anderson’s participation.
- The court found Anderson showed a sufficient likelihood of success on his ADA claim because the policy operated as a blanket disability-based exclusion without the required individualized safety assessment.
- The court found irreparable harm from exclusion from participation based on disability and concluded the balance of hardships and public interest favored temporary injunctive relief preserving the status quo.

## Legal Principles

- ADA Title III prohibits disability discrimination in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of a covered public accommodation.
- A safety-based exclusion under the ADA’s “direct threat” concept requires an individualized determination grounded in current medical knowledge or the best available objective evidence, not generalized assumptions.
- Blanket exclusions based solely on disability, without individualized evaluation and consideration of reasonable modification, are inconsistent with ADA requirements.
- A TRO may issue where the movant shows likelihood of success on the merits, irreparable harm, a favorable balance of hardships, and that the injunction is consistent with the public interest.

## Conclusion

The court temporarily barred Little League from enforcing its policy excluding wheelchair-using coaches from the on-field coach’s box because the policy was a categorical disability-based restriction unsupported by an individualized, objective safety assessment as required by ADA Title III, and immediate relief was necessary to prevent irreparable harm during tournament play.


Anderson v. Little League Baseball, Inc., 794 F. Supp. 342 (D. Ariz. 1992)