A. L. v. Walt Disney Parks and Resorts US, Inc., 50 F.4th 1097

Background

A.L. is an adult with severe autism (developmental age ~5–7) who relies on strict routines and may have "meltdowns" if routines and waiting requirements are not managed.
Disney replaced its unlimited Guest Assistance Card (GAC) with the Disability Access Service (DAS) in 2013 after widespread abuse of GAC; DAS issues return times allowing entry via the FastPass line and generally permits one active return time per guest.
On December 19, 2013 A.L.’s party received DAS plus a limited number of Re-admission (Re-ad) passes; family used some Re-ad passes early and left the park because they believed they lacked enough passes to ride A.L.’s preferred attractions in order.
A.L. sued under Title III of the ADA seeking either unlimited FastPass access or at least ten Re-ad passes per person, arguing DAS did not provide a "like" experience and was not sufficient to prevent meltdowns.
After a bench trial on remand the district court found A.L.’s requested modifications were neither necessary nor reasonable and would fundamentally alter Disney’s services; it entered judgment for Disney.
The Eleventh Circuit affirmed, holding there was no clear error in the district court’s factual findings, no legal error in the fundamental-alteration analysis, and no abuse of discretion in evidentiary rulings.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether A.L.’s requested modification was "necessary" (i.e., required to afford a like experience)	A.L.: DAS does not prevent meltdowns or give the ordered, on-demand access he needs; behavioral features of autism make his request necessary	Disney: DAS (with planning and Re-ad passes) provides a comparable or better "like" experience; A.L. can wait and be redirected	Court: Affirmed district court—A.L. failed to prove necessity; record supports ability to wait/redirect and DAS can provide a like experience
Whether modification was "reasonable"	A.L.: Ten Re-ad passes/unlimited FastPass are reasonable to avoid meltdowns	Disney: Modification would enable fraud/overuse and harm park operations; DAS is reasonable alternative	Court: A.L. abandoned the reasonableness argument on appeal; alternatively district court’s reasonableness finding is not clearly erroneous
Whether the requested modification would "fundamentally alter" Disney’s goods/services	A.L.: Court improperly focused on Disney’s business/aggregate impact instead of the individual’s needs	Disney: Aggregate application would increase wait times, recreate GAC abuse, and impair services for non-DAS guests	Court: Applied correct legal test (per Martin); affirmed that aggregate effects would fundamentally alter Disney’s services
Evidentiary and procedural rulings (expert depositions/testimony; internal communications)	A.L.: Exclusions of a neurologist and autism expert, and exclusion of internal communications, prejudiced his case	Disney: Many requests were untimely, waived, or would cause prejudice; admission of Disney expert was proper	Court: No abuse of discretion—objections waived or untimely, scheduling rules and prejudice justified exclusions, and admitting Disney’s expert caused no substantial prejudice

Key Cases Cited

A.L. ex rel. D.L. v. Walt Disney Parks & Resorts US, Inc., 900 F.3d 1270 (11th Cir. 2018) (prior panel decision framing "like experience" and necessity analysis under Title III)
PGA Tour, Inc. v. Martin, 532 U.S. 661 (U.S. 2001) (Supreme Court guidance on "fundamental alteration" analysis)
Baughman v. Walt Disney World Co., 685 F.3d 1131 (9th Cir. 2012) (discussing how nondisabled use guides the "like experience" inquiry)
Argenyi v. Creighton Univ., 703 F.3d 441 (8th Cir. 2013) (analysis on reasonable modifications to provide comparable access)
Galvan v. Walt Disney Parks & Resorts U.S., Inc., 425 F. Supp. 3d 1234 (C.D. Cal. 2019) (district court rejecting similar challenge to DAS as unnecessary)
Anderson v. City of Bessemer City, 470 U.S. 564 (U.S. 1985) (standard for reviewing factual findings for clear error)