Case Explained: PATTERSON V. SIX FLAGS THEME PARKS, INC., ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-07-24 Docket: 2:21-cv-02398-KJM-AC The ninth-circuit affirmed the district court’s judgment and permanent injunction against Six Flags Theme Parks, Inc., its parent company, and Park Management Corp for violating Title III of the Americans with Disabilities Act and California’s Unruh Act. The court applied a standard of review that examines factual findings for clear error, legal conclusions de novo, and the scope of the injunction for abuse of discretion, noting that appellate review of injunctive relief is correspondingly narrow due to the district court’s considerable discretion. The court held that the challenged monitoring provisions—including requirements for quarterly compliance reports, a three-year-and-thirty-day retention of jurisdiction, and access to records by plaintiff’s counsel—were not overbroad and constituted a proper exercise of the district court’s discretion. The court reasoned that these measures were necessary to provide complete relief to the plaintiff, who sought future accommodations at the park, and were supported by factual findings that Six Flags’ violations resulted from systemic training and policy failures rather than isolated negligence. The court found no showing that the monitoring provisions were overly burdensome to the defendant. The practical consequence is that the permanent injunction remains in effect, requiring Six Flags to make good faith efforts to provide reasonable accommodations to deaf or hard-of-hearing guests at its Discovery Kingdom park and national call center, subject to the affirmed monitoring and reporting obligations. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.