Facebook Defeats ADA Suit Involving Account Termination, Site Not ‘Public Accommodation’

• Case Summary:
  A Facebook account holder with bipolar disorder, whose account was terminated for apparent violations of the site’s terms of service, unsuccessfully argues that Facebook’s sale of gift cards in physical stores makes its online service a place of public accommodation under the Americans with Disabilities Act.
• Key Takeaway:
  In the Ninth Circuit, ADA claims must arise from alleged discrimination in physical places. ADA claims can only arise from alleged online discrimination in the Ninth Circuit if the online activity has an identifiable nexus to a disabled individual’s access to a physical place of public accommodation.

Facebook’s internet services ...