have applied the Weyer reasoning to ADA claims against insurance policies, the Ninth Circuit has yet to address whether its reasoning might extend to other entities. Furthermore, no Ninth Circuit opinions have articulated any specific test or factors a court should consider when assessing the extent to which a private entity must be connected to a physical place to qualify the entity as a “public accommodation” subject to the ADA. The Sixth and Third Circuits— courts the Ninth Circuit followed explicitly on this issue — have held that in order for Title III of the ADA to apply, some “nexus” must exist between the physical place of public accommodation and the services or privileges denied in a discriminatory manner. Menkowitz v. Pottstown Mem. Med. Ctr., 154 F.3d 113, 120 (3d Cir.1998) (<HOLDING>), discussed with approval in Martin v. PGA
holding that a hospital can conspire with members of its medical staff holding that a hospitals bylaws are an integral part of its contractual relationship with the members of its medical staff holding that hospitals denial of staff privileges to disabled doctor violated title iii because ada applies not only to members of the public seeking medical services but also to those wishing to work as doctors within hospital holding that ada claim under title iii did not survive plaintiffs death holding that public accommodation within meaning of title iii of ada includes more than actual physical structures