United States Court of Appeals For the Seventh Circuit
Civil Rights — ADA
Spring-hinged door closers in hotel rooms comply with the ADA.
“[T]he most reasonable interpretation of the 2010 Standards requires that we treat spring hinges and door closers separately and apply the separate standards accordingly. Contrary to the 1991 Standards, which had a general provision to govern all door closers, the 2010 Standards specifically carved out a separate regulation governing the closing speed of a spring hinge. This specific carve-out strongly undercuts Scherr’s argument that the DOJ intended that spring hinge devices to be regulated both by the specific Spring Hinge provision and the general Door Closer provision. If, as the district court noted, the DOJ intended to regulate the closing speeds of spring hinges under the Door Closer provision, it would not have needed to add a separate, specific provision, which provided a different closing speed, to regulate spring hinges. Furthermore, the Spring Hinge provision specifically refers to spring hinges as ‘door and gate spring hinges,’ which indicate that the DOJ expected spring hinges to be used as door closers and therefore carved out a specific regulation for them. If we were to read the statute as Scherr urges and apply the Door Closer provision to spring hinges, it would render superfluous the separate Spring Hinge provision and the different closing time specifically established for spring hinges. Because we do not construe regulations in such a way as to render other provisions of the regulations meaningless or superfluous, Scherr’s claim fails as a matter of law.3 See id. at 2330; see also In re Willet, 544 F.3d 787, 792 (7th Cir. 2008).”
Appeal from the United States District Court for the Northern District of Illinois, Norgle, J., Manion, J.