Anderson v. Little League Baseball Inc. (1992)

By Matthew Chin

Overview

Anderson v. Little League Baseball Inc. is a district court case that discusses the issue of a paraplegic coach coaching from the coaches' box near first and third base. Little League Baseball Inc. established a rule that prevented coaches in wheelchairs from being in the coaches’ box for the safety of the base runners. Lawrence O. Anderson sued Little League Baseball under Title III of the ADA, which prevents discrimination based on disability in public accommodations.

Summary

On July 24th, 1991, Little League Baseball and its president and chief executive officer, Dr. Creighton J. Hale, established a new rule which stated that coaches who are confined to a wheelchair would still be allowed to continue coaching from the dugout, but would be prohibited from being in the coaches' box. The reasoning that the defendants cited was that it creates safety issues for the players with the possibility of them running into the wheelchair. The plaintiff, who had injured his spinal cord, which confined him to a wheelchair, had been an on-field coach for the past three years. Despite that, the plaintiff still served as the on-field coach for the duration of the season until the season ended, as the local Little League refused to enforce the policy.

The defendants did not pursue enforcement at the time. Following the end of the 1991 season, several state district administrators, led by district administrator Mike Kayes, voted in opposition to the new policy and urged Little League to reverse its decision. The effort was unsuccessful, and the policy remained. The 1992 season began, and the local Little League continued to ignore the new policy, allowing the plaintiff to continue serving as an on-field base coach. However, the plaintiff claimed that the defendant was attempting to enforce the rule using threats of revoking their charter and taking away tournament privileges. Based on the defendant’s recent actions, the plaintiff was worried that the defendant would seek to prevent him from participating in the end-of-season tournament, where he was selected to coach the All-Star team in the tournament.

In response, the plaintiff filed for declaratory and injunctive relief and ordered a temporary restraining order on Little League Baseball, preventing them from interfering in order to enforce their policy. The court approved both the restraining order and the plaintiff’s request for a preliminary injunction at a later date. The reasoning stated by the court was that the defendant had no evidence that the plaintiff posed a serious danger to the players, based on his three years of coaching on the field without a single incident. Also, the fact that the defendant had made no attempts to conduct an individualized assessment to test to see if there was any legitimate threat to injury caused by the plaintiff being on the field or the likelihood of injury happening, and if there were measures to possibly mitigate the risk of injury if it was found out that the plaintiff's wheelchair did cause a chance of injury to the players. 

The court ruled in favor of the plaintiff, and he was able to continue coaching Little League from the coaches’ box. As for the defendant, the court granted the plaintiff his request for an injunction, not only preventing them from enforcing the rule nationwide, but also forcing them to repeal the rule altogether.

Impact

Despite being short and clear-cut, this case solidified two things. The first is that the ADA protects disabled individuals from blatant discrimination by public accommodations, which further enforces Title III’s promise to ensure “full and equal enjoyment” to disabled people in public accommodations. The second is that it sets a precedent that forces public accommodations to conduct tests and establish evidence that shows that such accommodations, such as wheelchairs, do pose a threat to others and cannot simply draft and impose discriminatory rules, specifically against disabled individuals, on the basis of an assumption that there may be some risk of injury.

Court Documents

Anderson v. Little League Baseball, Inc., 794 F. Supp. 342 (D. Ariz. 1992), https://law.justia.com/cases/federal/district-courts/FSupp/794/342/1477176/ 

Citations

Studicata. “Anderson v. Little League Baseball, Inc. – Case Brief Summary – Facts, Issue, Holding & Reasoning.” Studicata. Accessed September 19, 2025. https://www.studicata.com/case-briefs/case/anderson-v-little-league-baseball-inc.