Introduction

Binno v. American Bar Association is a pivotal case adjudicated by the United States Court of Appeals for the Sixth Circuit on June 16, 2016. The plaintiff, Angelo Binno, a legally blind individual, challenged the American Bar Association's (ABA) accreditation standards under the Americans with Disabilities Act (ADA). Binno asserted that the mandatory Law School Admission Test (LSAT), as regulated by the ABA, discriminates against visually impaired applicants by incorporating spatial reasoning and visual diagramming questions, thereby hindering his admission to law schools and violating ADA Titles III and V.

Summary of the Judgment

The Sixth Circuit affirmed the district court's decision to dismiss Binno's lawsuit against the ABA. The court concluded that Binno lacked standing to sue the ABA under Article III of the Constitution, primarily because his alleged injury was not directly caused by the ABA’s actions and was unlikely to be remedied by a favorable court decision. Additionally, even if standing were established, the court found that Binno's claims under ADA Titles III and V were insufficient to state a plausible claim for relief. A concurring opinion by Judge Griffin disagreed with the majority regarding standing but concurred on the dismissal of ADA claims.

Analysis

Precedents Cited

The judgment extensively references foundational cases that define the contours of Article III standing and ADA compliance:

• LUJAN v. DEFENDERS OF WILDLIFE (504 U.S. 555): Established the three-pronged test for constitutional standing.
• WARTH v. SELDIN (422 U.S. 490): Emphasized that courts must construe complaints in favor of the plaintiff and accept factual allegations as true.
• Coyne v. American Tobacco Co. (183 F.3d 488): Clarified aspects of standing related to constitutional claims.
• Imhoff Investing LLC v. Alfoccino, Inc. (792 F.3d 627): Reinforced the threshold nature of standing in federal jurisdiction.
• Ashcroft v. Iqbal (556 U.S. 662): Introduced the plausibility standard for claims to survive motions to dismiss.
• GRATZ v. BOLLINGER (539 U.S. 244): Discussed the concept of injury-in-fact in the context of higher education admissions.
• Lexmark International, Inc. v. Static Control Components, Inc. (134 S. Ct. 1377): Highlighted that standing is not a zero-sum game.

These precedents collectively informed the court's assessment of Binno's standing and the viability of his ADA claims.

Legal Reasoning

The court's analysis hinged on two primary legal questions: whether Binno had standing to sue the ABA and whether his ADA claims were legally sufficient.

1. Standing

Injury-in-Fact: Binno alleged personal grievances stemming from the LSAT's format, claiming emotional distress and diminished competitive standing due to his visual impairment. The court acknowledged this as a potentially concrete injury.

Causation: The central contention was whether the ABA's policies directly caused Binno's injury. The ABA argued that it neither developed the LSAT nor controlled its administration, asserting that the Law School Admission Council (LSAC) was responsible. The majority sided with the ABA, finding insufficient causation, while Judge Griffin disagreed, emphasizing that the ABA's standards effectively mandated the LSAT, thereby establishing a traceable link.

Redressability: The court examined whether a favorable ruling could alleviate Binno's alleged harm. The majority concluded that even if the ABA's standards were struck down, law schools might still require the LSAT, rendering redressability unlikely. Judge Griffin, however, argued that the ABA's standardized requirements were central to the issue and that altering these standards could directly benefit plaintiffs like Binno.

2. ADA Claims

Under Title III, Binno claimed that the ABA "offered" a discriminatory exam by enforcing LSAT requirements without adequate accommodations. The court found this interpretation unpersuasive, noting that "offering" in ADA terms implies direct control over exam administration, which the ABA lacked. Similarly, under Title V, Binno argued that the ABA interfered with his ADA rights. The majority dismissed this claim, citing the lack of direct ADA violations by the ABA.

Impact

The dismissal of Binno's case underscores the critical importance of standing in federal litigation. By setting a precedent that accreditation bodies like the ABA may not be directly liable under certain ADA provisions unless a clear causal link is established, this judgment may limit future attempts by individuals to challenge standardized examinations on disability grounds. However, Judge Griffin's concurrence suggests that there remains room for argument regarding the ABA's responsibility, potentially influencing future appellate decisions or prompting legislative clarifications on accreditation bodies' obligations under the ADA.