Substantial Equivalence of Wheelchair-Accessible Stadium Seating Under the ADA

Introduction

The case of David Felimon Cerda v. Chicago Cubs Baseball Club, LLC (7th Cir. 2025) arises from the renovation of historic Wrigley Field between 2014 and 2019. Plaintiff‐appellant David Cerda, a motorized wheelchair user, sued the Chicago Cubs under Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12101–213, and related statutes, claiming that the remodeled ballpark did not provide the required 209 wheelchair‐accessible seating locations “substantially equivalent” to other spectator seats. After a five‐day bench trial, the district court held that Wrigley Field met the ADA standards, and this appeal followed. Key issues include:

Whether Cerda had standing to challenge seating in premium areas (e.g., the 1914 Club).
Whether the renovated ballpark provides at least 209 qualifying wheelchair‐accessible locations under the 2010 ADA Standards for Accessible Design.
Whether seating in the Terrace (200 Level) with partially obstructed views can be deemed “substantially equivalent,” particularly when many wheelchair patrons prefer those seats.
How much front‐to‐back “toe room” counts toward accessible space in the 300 Level seating.

Summary of the Judgment

The Seventh Circuit affirmed. The court held:

Cerda lacks standing to challenge the 1914 Club because he never sought membership or was ever invited to use that facility.
Wrigley Field’s renovated seating meets or exceeds the 209‐space minimum: the Cubs demonstrated at least 225 qualifying spaces under the 2010 Standards, and a later consent decree with the United States requires even more improvements, bringing the total to at least 217 accessible spots.
Seating in the Terrace, although partially obstructed, is “substantially equivalent” because non‐handicapped patrons face the same obstructions and wheelchair patrons overwhelmingly choose those locations for reasons of access, shelter, and price.
The district court did not clearly err in its factual findings, and its interpretation—that minimal toe space under a railing counts toward the required front‐to‐back depth—is a legal interpretation afforded deference in light of the subsequent federal consent decree.

Analysis

Precedents Cited

Americans with Disabilities Act, Title III (42 U.S.C. §§ 12181–12189): Requires equal access in public accommodations and directs the Attorney General to adopt regulations consistent with Access Board guidelines.
2010 Standards for Accessible Design (28 C.F.R. Pt. 36, App. A, B): Implement Access Board guidelines, mandating at least 209 wheelchair locations, distributed throughout a venue with “substantially equivalent” viewing angles.
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992): Defines Article III standing—injury‐in‐fact, causation, redressability.
U.S. Bank N.A. v. Village at Lakeridge, LLC, 583 U.S. 387 (2018) & Bufkin v. Collins, 145 S. Ct. 728 (2025): Clarify the standard of appellate review—plenary for legal issues, deferential for factual findings (clear‐error review per Fed. R. Civ. P. 52(a)(6)).
United States v. Chicago Baseball Holdings, LLC (N.D. Ill. 2022): Government ADA enforcement suit resolved by consent decree requiring additional accessible seating modifications at Wrigley Field.

Legal Reasoning

The Seventh Circuit’s reasoning proceeded in several steps:

Standing: Applying Lujan, the court held Cerda had no concrete plan or invitation to join the fee‐based, invitation‐only 1914 Club and therefore no injury to litigate that claim.
Count of Accessible Spaces: Both parties agreed the 2010 Standards govern, requiring 209 distributed locations. The Cubs presented evidence of 225 such spots. Cerda’s challenges to particular areas (e.g., Batter’s Eye, luxury boxes) either failed on standing or factual grounds.
“Substantially Equivalent” in the Terrace: The district court found that obstructed‐view seats are the norm in the Terrace, and that wheelchair patrons prefer those locations for reasons of proximity to elevators, shelter, and cost. Under clear‐error review, the appellate court could not overturn these fact‐intensive findings.
Toe Room in the 300 Level: Interpreting the 2010 Standards, the district court counted minimal toe‐space under a railing as part of the front‐to‐back dimension. A purely legal question, but the subsequent consent decree—approved by the district court in the government’s ADA enforcement action—demonstrates that the parties and the court view this interpretation as acceptable, mooting further dispute here.

Impact

This decision will guide future ADA Title III litigants and venues undergoing renovation:

Courts will defer to detailed factfinding on “substantially equivalent” viewing angles where wheelchair users themselves express a preference for certain seats.
Challenges to inaccessible premium or private spaces must clear Article III standing thresholds—membership or invitation is critical.
Consent decrees in parallel government enforcement actions can shape interpretations of technical regulatory standards and inform private‐party litigation.
Stadium designers and operators can rely on user preferences and pricing differentials as evidence that accessible seating meets statutory benchmarks.

Complex Concepts Simplified

“Substantially Equivalent” Viewing Angle: The ADA does not demand the exact same sightline for wheelchair users; it requires options that are comparable in location, choice, and viewing quality. If non‐disabled patrons tolerate obstructions in a section, similar spots count for wheelchair users when they choose them.
Standing: A plaintiff must show a real and imminent injury directly caused by the defendant and that a court decision can remedy it. Simply wanting to enter a members‐only club does not suffice if membership is discretionary and expensive.
Clear-Error Review: Appellate courts accept a trial judge’s factual findings unless a mistake is obvious. Mixed questions that lean heavily on facts get this deferential treatment.
Toe Room: Regulations measure the length of an accessible space from front to back. Even small areas where one can tuck in toes under a barrier may count toward the required 30 inches of depth.

Conclusion

The Seventh Circuit’s decision in Cerda v. Chicago Cubs underscores that renovating historic venues under the ADA involves both legal interpretation and detailed factual assessment. Key lessons include:

Deference to trial courts on complex, site‐specific fact questions—especially when wheelchair users endorse the challenged designs.
The importance of user choice and preference as evidence of compliance.
The necessity for plaintiffs to establish concrete injury and redressability when attacking private or exclusive facilities.

By affirming the district court and recognizing the later federal consent decree, the Seventh Circuit sets a practical benchmark for sports venues and other public accommodations striving to meet ADA standards without sacrificing functionality or historic character.