Matheis v. CSL Plasma, Inc. (2019)

By Abigail Lentine 

Overview

Matheis v. CSL Plasma, Inc. is a federal civil rights case that further investigated how the Americans with Disabilities Act (ADA) is applied. The case focuses on George Matheis, an individual with a service animal, who was denied the opportunity to donate plasma at a CSL Plasma facility. After Matheis highlighted that he had previously donated without an issue, he was told he could not donate unless he provided a doctor’s note stating he could be present without the service animal. In the end, the case is about whether CSL's strategy violated the ADA by relying on general guidelines instead of a personal assessment.

Summary

George Matheis was gifted a service dog to help cope with his post-traumatic stress disorder and anxiety. As a retired officer, Matheis struggled with panic attacks and socialization issues that his service animal, Odin, helped him cope with. In efforts to raise extra money, Matheis has previously visited the CSL Plasma facility approximately ninety times in 2016. Upon his next visit with his service animal, Matheis was denied further entry into the donation center. CSL informed him that its policy prevented individuals who use service animals for illnesses like anxiety or depression from donating [1]. 

Even though CSL allowed service animals for other disabilities, such as guide dogs for individuals who are blind, Matheis’s service animal was not seen as a necessity. Although Matheis offered to leave his service animal in the car, CSL required a doctor’s note stating that he could donate without the service animal before allowing him to return, effectively treating psychiatric disabilities differently from other recognized disabilities [2]. 

The case was first heard in the Middle District of Pennsylvania, US District Court, which sided with CSL. The court agreed that CSL had to follow the Americans with Disabilities Act, but it also believed the company's claim that its policy was based on safety concerns for the recipients. Matheis appealed the decision, arguing that CSL’s policy relied on assumptions about people who use psychiatric service animals rather than a personal evaluation of his ability to safely donate plasma. Matheis stated he had made many successful donations in the past and was denied the ability to receive the pre-donation screening necessary to verify his condition before donating [1]. 

On appeal, the Third Circuit disagreed with the district court’s reasoning and took a closer look at whether plasma donation centers should be treated as a place of public accommodation under the ADA. The court argued that the CSL donation center functions like any other business. Using the comparison of banks or recycling center donors, the court points out that while the plasma donors are not paying money, they are providing plasma, which the company then sells for profit. Due to this, the court rejected the argument that plasma centers fall outside the ADA simply because they pay donors rather than charge them. The court made clear that what matters is whether the business offers a service to the public [1]. 

Once CSL was deemed a place of public accommodation/service establishment, it had to follow the ADA's rules on fair accommodations and could not use general rules that resulted in discrimination. The Third Circuit held that CSL Plasma violated the Americans with Disabilities Act, and the district court’s decision was reversed [1].

Impact

The decision in Matheis v. CSL Plasma, Inc. affects how the ADA is applied. This case limited how businesses could use assumptions to determine whether disabled customers can use their services. The court confirmed that plasma donation centers are places of public accommodation and must follow ADA standards like other service businesses. The decision also emphasizes that safety concerns must be based on actual evidence, not generalizations about mental health or service animal use. The case requires individualized assessments and reinforces that psychiatric disabilities are legal disabilities like physical ones.

Court Document 

[1] Matheis v. CSL Plasma, Inc., No. 18-3415, United States Court of Appeals for the Third Circuit (2019), https://www.govinfo.gov/content/pkg/USCOURTS-ca3-18-03415/pdf/USCOURTS-ca3-18-03415-0.pdf 

Citations

[2] Matheis v. CSL Plasma, Inc., Third Circuit case summary, Studicata, https://www.studicata.com/summaries/united-states-court-of-appeals-third-circuit/matheis-v-csl-plasma-inc-2019-t8wc7x/