## Facts

- George F. Matheis, Jr., a retired police officer with PTSD, routinely donated plasma at CSL Plasma, Inc.’s facility, doing so about 90 times over 11 months without incident.
- After obtaining a psychiatric service dog (Odin), Matheis brought the dog to the donation center.
- CSL enforced a policy treating individuals who use a service animal to manage anxiety as categorically unsafe to donate plasma.
- CSL refused to allow Matheis to donate unless he provided a physician letter stating he had no need for a service animal before CSL would screen him for further donations.
- Matheis sued under Title III of the Americans with Disabilities Act (ADA), alleging discrimination by a place of public accommodation.
- The district court entered judgment for CSL; Matheis appealed, and CSL filed a cross-appeal.

## Issues

1. Whether a plasma donation center qualifies as a “service establishment” and thus a “public accommodation” under ADA Title III, 42 U.S.C. § 12181(7)(F).
2. Whether Title III is violated when a plasma center imposes a blanket ban on prospective donors who use a psychiatric service animal, rather than making an individualized, evidence-based assessment of risk.

## Decision

- The Third Circuit reversed and remanded.
- The court held plasma donation centers are “service establishments” covered by Title III.
- The court held CSL violated the ADA by imposing a categorical exclusion on donors who use psychiatric service animals and by conditioning access on a doctor’s letter negating the need for the service animal.
- The court rejected CSL’s position that donors are merely “suppliers” and thus outside Title III’s scope, emphasizing the donor-facing services (screening, medical evaluation, and plasma extraction) provided to members of the public.

## Legal Principles

- Plasma donation centers are “public accommodations” under ADA Title III because they fall within the statutory category of “other service establishment” in 42 U.S.C. § 12181(7)(F).
- A public accommodation must generally permit a person with a disability to be accompanied by a service animal; exclusion is permitted only within narrow regulatory exceptions (e.g., animal out of control, not housebroken, fundamental alteration, or direct threat).
- Any “direct threat” or safety-based exclusion must rest on an individualized assessment grounded in actual risk, not speculation, stereotypes, or generalizations about disability or service-animal use.
- Blanket bans on individuals who use psychiatric service animals, without individualized assessment, violate Title III.

## Conclusion

The Third Circuit held that plasma donation centers are ADA Title III public accommodations and that CSL’s categorical policy barring donors who use psychiatric service animals unlawfully discriminated by denying access without an individualized, evidence-based safety assessment.


Matheis v. CSL Plasma, Inc., 936 F.3d 171 (3d Cir. 2019)