Summary
The Fifth Circuit affirmed injunctive relief and a $20,000 damages award against SMG in an action involving alleged disability discrimination at the Mercedes-Benz Superdome. The court held that Smith had standing to seek injunctive relief and that the Louisiana Human Rights Act did not require intentional discrimination for a public-accommodation claim. The court vacated the injunction against Kyle France because it was insufficiently specific as to the actions required of him.
Topics
Practice areas
Questions Presented
- Whether Smith had Article III standing to seek injunctive relief under the ADA.
- Whether the district court abused its discretion in granting injunctive relief against SMG and France.
- Whether the Louisiana Human Rights Act requires intentional discrimination to establish discrimination by a place of public accommodation.
- Whether the $20,000 compensatory-damages award against SMG was excessive or an abuse of discretion.
Holdings
- Smith had standing to pursue injunctive relief because her history of attending events at the Superdome and stated intent to return if the accessibility issues were resolved established a sufficiently real and immediate threat of future injury.
- The district court did not abuse its discretion by entering an injunction against SMG requiring accessibility-related policy revisions, employee training, and public accessibility information.
- The injunction against France had to be vacated because it did not identify with sufficient specificity what France was required to do or forbidden from doing.
- The Louisiana Human Rights Act does not require a plaintiff alleging discrimination by a place of public accommodation to prove intentional discrimination.
- The $20,000 compensatory-damages award against SMG was neither excessive nor an abuse of discretion.
Key quotations
“Nevertheless, “a disabled individual” seeking an injunction under the ADA, “need not engage in futile gestures before seeking an injunction; the individual must show only that [the alleged violation] actually affects his activities in some way.”” (6)
“The district court abused its discretion by not identifying “what the court intends to require and what it means to forbid” as to France.” (8)
Factual background
Smith, who had a left-leg amputation, purchased tickets she believed were wheelchair-accessible for a Guns N’ Roses concert at the Mercedes-Benz Superdome. The seats were ordinary folding chairs surrounded by other chairs, and an SMG employee refused to remove the chair or tell Smith about an available wheelchair-accessible seat, instead offering to store her wheelchair while she remained in the seat with crutches. Smith testified that she felt anxious and vulnerable and could not see the concert because surrounding patrons were standing. She had previously attended events at the Superdome ten to fifteen times and intended to return if the accessibility issues were resolved.
Procedural history
Smith sued SMG and Louisiana public-entity officials over alleged disability discrimination at the Mercedes-Benz Superdome. After cross-motions for summary judgment, the district court dismissed or resolved certain claims based on sovereign immunity and voluntary dismissals, conducted a bench trial on three remaining claims, entered judgment for Smith, awarded $20,000 in compensatory damages against SMG, and entered ADA injunctions against SMG and France. The Fifth Circuit affirmed the relief against SMG but vacated the injunction against France.