Angelo Binno v. The American Bar Association, 826 F.3d 338

Background

Angelo Binno, a legally blind applicant, sued the American Bar Association (ABA) under the ADA after failing to gain admission to several law schools; he blamed poor LSAT performance (particularly the analytical‑reasoning "logic games") for his denials.
The ABA is the recognized accreditor of U.S. law schools and promulgates Standard 503, which requires law schools to require applicants to take a "valid and reliable" admission test; the ABA accords presumptive validity to the LSAT but permits alternatives subject to school‑level justification or a programmatic variance.
The LSAT is developed and administered by the Law School Admission Council (LSAC), which handles test content and disability accommodations; the ABA does not create or administer the LSAT or directly grant accommodations.
Binno sought only equitable relief (declaratory and injunctive), asking the court to enjoin ABA enforcement of Standard 503 and bar it from accrediting schools that require the LSAT without accessible arrangements or waivers for the blind.
The district court dismissed for lack of Article III standing (causation and redressability defects) and, alternatively, for failure to state Title III and Title V ADA claims; the Sixth Circuit affirmed, holding Binno lacked standing and, in any event, failed to state plausible claims against the ABA.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing — causation	Standard 503 effectively compels law schools to require the LSAT, so ABA caused Binno's injury.	ABA does not create/administer LSAT or control law schools' admissions decisions; LSAC and law schools are the true sources.	No standing: injury not fairly traceable to ABA because it does not control LSAT content or administration.
Standing — redressability	Declaring Standard 503 unlawful would free schools to waive LSATs for Binno, redressing his injury.	Even if Standard 503 were struck down, law schools could still require the LSAT; relief might not redress injury.	No standing: relief against ABA unlikely to redress harm because third‑party schools/LSAC remain free to act.
Title III (42 U.S.C. §12189) — "offers" examinations	ABA "offers" the LSAT via accreditation policy and thus must ensure accessible place/manner or alternatives.	Section 309 applies to entities that administer/select the exam or control its place/manner; ABA lacks that operational control.	Dismissed: Binno failed to plead facts showing ABA controls administration or can provide accommodations; Title III claim not plausible.
Title V (42 U.S.C. §12203(b)) — interference	Standard 503 "interferes" with Title III rights by preventing individual LSAT waivers.	Without an underlying Title III violation and absent facts that ABA interferes with test administration, no Title V violation.	Dismissed: No adequate allegations that ABA interfered with the exam's administration or accommodations; Title V claim fails.

Key Cases Cited

Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing doctrine components)
Warth v. Seldin, 422 U.S. 490 (pleading standard for standing allegations)
Ashcroft v. Iqbal, 556 U.S. 662 (plausibility pleading standard)
Bell Atlantic v. Twombly, 550 U.S. 544 (plausibility standard)
Parsons v. U.S. Dep’t of Justice, 801 F.3d 701 (6th Cir.) (standing where third‑party response traced to defendant)
Federal Election Comm’n v. Akins, 524 U.S. 11 (redressability can exist despite agency discretion)
Gratz v. Bollinger, 539 U.S. 244 (injury from inability to compete on equal footing)