42 U.S.C. § 12187

Exemptions for private clubs and religious organizations

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The provisions of this subchapter shall not apply to private clubs or establishments exempted from coverage under title II of the Civil Rights Act of 1964 (42 U.S.C. 2000–a(e)) [42 U.S.C. 2000a et seq.] or to religious organizations or entities controlled by religious organizations, including places of worship.

Notes of Decisions
Cited in 41 cases (9 in the last 5 years), 1997–2026 · leading case: Reed v. Columbia St. Mary's Hosp., 915 F.3d 473 (7th Cir. 2019).
Reed v. Columbia St. Mary's Hosp., 915 F.3d 473 (7th Cir. 2019). · cites it 4× “Id. at 1105-08 . We reverse. The hospital raised its religious exemption affirmative defense to the ADA claims for the first time after discovery, in its motion for summary judgment.”
PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001). · cites it 4× “[10] Title 42 U. S. C.§ 12187 provides: "The provisions of this subchapter shall not apply to private clubs or establishments exempted from coverage under Title II of the Civil Rights Act of 1964 (42 U.”
Samantha Ring v. Boca Ciega Yacht Club Inc., 4 F.4th 1149 (11th Cir. 2021). · cites it 3× “The club responded that it was covered by an exception for “private clubs or establishments exempted from coverage under title II of the Civil Rights Act of 1964,” 42 U.S.C. § 12187 , and it refused the member’s request for an exception to its pet policy.”
Woods v. Wills, 400 F. Supp. 2d 1145 (E.D. Mo. 2005). · cites it 4× “[6] Defendants assert that as a religious organization they cannot be sued under Title III because 42 U.S.C. § 12187 provides an exemption for "private clubs or establishments exempted from coverage under title II of the Civil Rights Act of 1964 (42 U.”
Equal Emp. Opportunity Comm'n v. St. Francis Xavier Parochial Sch. & St. Francis Xavier Church, 117 F.3d 621 (D.C. Cir. 1997). “42 U.S.C. § 12187 . The district court did not address the religious institution exemption because it dismissed the case on independent grounds.”
Chris Langer v. Milan Kiser, 57 F.4th 1085 (9th Cir. 2023). “We rested our holding on the text of 42 U.S.C. § 12187 , which states that Title III of the ADA “shall not apply to private clubs or establishments exempted from coverage under Title II of the Civil Rights Act.”
Marshall v. Sisters of Holy Fam. of Nazareth, 399 F. Supp. 2d 597 (E.D. Pa. 2005). · cites it 2× “, supra; 42 U.S.C. § 12187 . As I find that Nazareth Academy qualifies for the religious exemption and that plaintiff cannot demonstrate a disability, I will grant summary judgment in Nazareth’s favor.”
White v. Denver Seminary, 157 F. Supp. 2d 1171 (D. Colo. 2001). · cites it 3× “” 42 U.S.C. § 12187 ; PGA Tour, 121 S.Ct. at 1897 n.”
Reed v. Columbia St. Mary's Hosp., 236 F. Supp. 3d 1091 (E.D. Wis. 2017). · cites it 3× “She also asserts *1101 that disputes of fact preclude a ruling at this time as to whether Columbia qualifies for the religious exemption.”
Rose v. Cahee, 727 F. Supp. 2d 728 (E.D. Wis. 2010). · cites it 2× “§ 12182 (a); 42 U.S.C. § 12187 . The statute does not define what it means to be a “religious organization” or to be “controlled” by one.”
Indep. Living Resources v. Oregon Arena Corp., 982 F. Supp. 698 (D. Or. 1997). “Notwithstanding the use of the label "private” in the briefs, these suites are not “private clubs or establishments” for purposes of 42 U.S.C. § 12187 , and do not qualify for that exemption from the requirements of Title III.”
Kalani v. Castle Vill. LLC, 14 F. Supp. 3d 1359 (E.D. Cal. 2014). · cites it 2× “Defendants assert that (1) the court lacks subject matter jurisdiction because the mobile home park is not a public accommodation, (2) the Clubhouse is a “private club” and therefore exempt from the ADA pursuant to 42 U.S.C. § 12187 (incorporating 42 U.S.C.”
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