Crane v. Lifemark Hosp. of Fla., Inc.

We review the decision of the Florida Commission on Human Relations which held that it lacked jurisdiction to adjudicate a complaint filed by Harold Crane, who is deaf, against Lifemark Hospital of Florida, Inc., for failure to provide an American Sign Language interpreter. The issue on appeal is whether a private hospital in Florida constitutes a “public accommodation” under the Florida Civil Rights Act of 1992 by virtue of having a cafeteria within its premises. Based on express language in the Act that excludes cafeterias in hospitals from the provisions of the Act, we agree with the…