Laboratory Corporation of America Holdings v. Davis

The Court applied the Article III standing doctrine to disability-access class actions by examining whether deterrence from using LabCorp's inaccessible facilities—allegedly caused by the known barriers in patient service centers—constitutes a concrete injury-in-fact for class members who had never personally visited a LabCorp location. Under TransUnion, the question was whether a reasonable fear of encountering barriers, combined with evidence that plaintiffs avoided LabCorp services because of those barriers, satisfied the particularized injury requirement for each absent class member or whether Article III required direct personal experience of the accessibility defect. The Court had to balance the practical reality of disability-based deterrence—that people with mobility disabilities may reasonably avoid facilities known to be inaccessible—against the constitutional requirement that federal jurisdiction rest on individualized, concrete injury.