Disabled Rights Action Committee v. Las Vegas Events, Inc.

The central question in this Americans with Disabilities Act (ADA) suit is whether the two private entities that stage the National Finals Rodeo at a publicly-owned arena in Las Vegas “operate” the arena during the Rodeo, and so are-responsible for assuring compliance with the ADA’s public accommodation physical accessibility requirements-. The district court thought not. Also at issue is whether the suit- can proceed without' the participation of the University and Community College System of Nevada (University System), the owner of the arena. The district court ruled that under Rule 19-of the Federal Rules of Civil Procedure, it cannot.

We conclude that under the circumstances here, the private groups staging the Rodeo did “operate” the publicly-owned facility during the Rodeo and so can be sued under Title III of the ADA for failure to. make a place of public accommodation accessible for disabled individuals. We further conclude that University System is not a necessary party under Rule 19.

I. BACKGROUND

A. Factual History

Disabled Rights Action Committee (Disabled Rights) is a- non-profit organization that advocates for the rights of people with disabilities. Its 1000-plus…