Nicholas Conti

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Central to this article is the significant Disability Rights Movement, which aimed to provide equal opportunity and equal access to people with disabilities, while rallying against negative stereotypes and advocating for institutional change. In Martinez v. Cot’n Wash, Inc., the California Court of Appeal for the Second District applied a strict method of textual interpretation to decide that, absent any nexus to a physical location or storefront, a website by itself cannot constitute a place of public accommodation under Title III of the ADA. Part II provides an overview of the Americans with Disabilities Act, focusing on a modern conflict emerging from the prominent rise in Title III claims under the ADA. Part III discusses the congressional intent behind the ADA. Part IV provides a historical background of the federal circuit split on determining places of public accommodation, particularly focusing on Ninth Circuit precedent. Part VI analyzes the majority opinion in Martinez, set forth by Presiding Justice Frances Rothschild’s strict method of textual interpretation for Title III of the ADA. Part VII explains the significance of the Martinez decision and the disproportionate impact that this federal circuit split has on the lives of individuals with disabilities. Finally, Part VIII is a brief conclusion of this case note, reiterating the harmful reality of the Martinez decision and analogous Ninth Circuit precedent.

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