Summary
The court affirmed a Maryland stadium ruling requiring access beyond listening devices for three spectators who could not benefit from those devices; the opinion expressly lacks binding precedential status in the circuit.
Key findings
- The decision of 25 March 2011 affirmed the District of Maryland judgment concerning FedEx Field in Landover. Page 2 states that unpublished opinions are not binding precedent in the circuit.
- Pages 4-5 describe three deaf or hard-of-hearing plaintiffs unable to benefit from the stadium’s assistive listening devices. Pages 22-25 hold that, in this stadium context, access beyond those devices was needed for game information, emergency and public announcements, and music and entertainment words carried by the public-address system.
- The majority affirmed a declaratory judgment requiring auxiliary access but did not require a particular form of aid. Page 11 records that the district court declined to order captioning as the specific means of access to lyrics and that typed lyrics were then made available before games.
- The defendants did not assert undue burden or fundamental alteration as defences to the content at issue. The majority treated what effective communication required as dependent on the goods and services offered in context.
- The partial dissent agreed that the listening devices did not effectively communicate to these plaintiffs, but disputed the breadth of the declaration about access to all aural content and argued for evaluating the effectiveness of the aids actually supplied.
Limits
This is a historical, unpublished appellate opinion about three litigants and one stadium, not a technology comparison or a statement of current law across all US jurisdictions. Captioning was central to the litigation; it is included only to show the boundary of the venue listening path for people who could not use it. No claim is made that the court ordered another listening-system technology.
Read the original
www.ca4.uscourts.gov/opinions/Unpublished/091021.U.pdf
Cited in
Cite this source
US Court of Appeals for the Fourth Circuit. Feldman v. Pro Football, Inc., Nos. 09-1021 and 09-1023 (unpublished opinion). 25 March 2011. https://www.ca4.uscourts.gov/opinions/Unpublished/091021.U.pdf (accessed 13 October 2026).
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