Michigan Flyer LLC v. Wayne County Airport Authority
860 F.3d 425
6th Cir.2017Background
- Michigan Flyer (a public-transport carrier) and its parent Indian Trails supported two disabled plaintiffs who sued Wayne County Airport Authority over moving a curbside bus stop; after settlement, Michigan Flyer alleges the Airport retaliated by favoring other carriers.
- Plaintiffs sued the Airport under Title V of the ADA, alleging retaliation in violation of 42 U.S.C. § 12203(a).
- The district court dismissed the complaint, concluding the statute’s use of “individual” does not cover corporate entities; plaintiffs moved to reopen under Rule 59(e) and to amend; the district court denied reopening and attorney’s fees to the Airport.
- Plaintiffs sought leave to amend to (1) add allegations that Airport’s conduct targeted a natural person (an officer) and (2) add a Title II ADA claim; district court denied as untimely and futile.
- The Sixth Circuit AFFIRMED: it held “individual” in § 12203(a) unambiguously means natural persons (not corporations), upheld the Rule 59(e) denial for lack of intervening change or manifest injustice, and upheld the district court’s discretion in denying attorneys’ fees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether “individual” in 42 U.S.C. § 12203(a) includes corporations | "Individual" should be read broadly to protect corporate entities that assist disabled persons; ADA remedial purpose and DOJ regulation support broad reading | "Individual" ordinarily means a natural person; Congress used both "person" and "individual" in § 12203(a), implying distinct meanings | The term is unambiguous and denotes natural persons only; corporations are not covered |
| Whether DOJ regulation compels broader reading of "individual" | DOJ uses "person" in its illustration and thus intended broader protection including entities | Statute is unambiguous; deference to agency not warranted; DOJ regulation itself uses "individual" elsewhere | Agency interpretation not applicable because statutory text is clear; regulation does not change meaning |
| Whether Rule 59(e) relief to amend should be granted after dismissal | Plaintiffs sought to add natural-person-targeting facts and a Title II claim after adverse judgment | District court argued plaintiffs delayed strategically and had earlier opportunities to amend | Denial affirmed—no intervening change in controlling law and no manifest injustice; plaintiffs’ delay was strategic |
| Whether prevailing defendant (Airport) should receive attorneys’ fees | Plaintiffs argued the suit was a reasonable (novel) attempt to vindicate rights | Airport sought fees as prevailing party | District court did not abuse discretion denying fees given unsettled law and reasonable grounds; fee award not required |
Key Cases Cited
- Mohamad v. Palestinian Auth., 566 U.S. 449 (2012) ("individual" ordinarily means a natural person)
- Clinton v. City of New York, 524 U.S. 417 (1998) (interpreting "individual" as synonymous with "person" in that statutory context)
- Perrin v. United States, 444 U.S. 37 (1979) (words not defined in a statute take ordinary meaning)
- Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (2009) (statutory construction begins with ordinary meaning of wording)
- Christiansburg Garment Co. v. EEOC, 434 U.S. 412 (1978) (prevailing defendants may receive fees only if plaintiff's claim was frivolous, unreasonable, or without foundation)
- Leisure Caviar, LLC v. U.S. Fish & Wildlife Serv., 616 F.3d 612 (6th Cir. 2010) (heightened burden to amend after adverse judgment; Rule 59(e) relief limited)