Spector v. Norwegian Cruise Line Ltd.

Background

A group of disabled travelers and their companions sued a cruise line after buying round‑trip tickets for NCL cruises that departed from Houston. The cruises were run by a Bermuda corporation with headquarters in Miami, but the ships were registered in the Bahamas and flew foreign flags. The travelers said the company discriminated under Title III of the Americans with Disabilities Act by charging higher fares and extra surcharges to disabled passengers, keeping evacuation plans and equipment in places they could not reach, requiring medical waivers or companions, threatening to remove passengers who disturbed others, and failing to remove physical access barriers in cabins and public areas. The District Court said Title III applies generally but dismissed structural barrier claims because federal agencies had not issued ship guidelines; the Fifth Circuit held Title III did not apply to foreign‑flag ships.

Reasoning

The Supreme Court reversed. It said Title III reaches foreign‑flag cruise ships in U.S. waters except where applying the law would interfere with a ship’s internal affairs. The Court emphasized that the ADA’s barrier‑removal rule only requires changes that are “readily achievable,” a standard that includes factors beyond cost and looks at the effect on ship operation. If a modification would conflict with international obligations like SOLAS or would threaten shipboard safety, it is not readily achievable and need not be made. The Court directed lower courts to analyze claims case‑by‑case and to consider safety and international law.

Real world impact

The ruling permits many non‑structural claims—pricing, policies, and services—to go forward against foreign cruise lines operating from U.S. ports, while structural changes face stricter review. The decision reverses the appeals court and sends the case back for further proceedings to sort fact‑specific safety and treaty issues.