Christopher Mielo v. Steak 'N Shake Operations, Inc.

Summary

The Third Circuit held that disability rights plaintiffs had Article III standing based on concrete injuries from encountering steep slopes in parking facilities, but reversed class certification under Rule 23(a) for failure to satisfy numerosity and commonality. The court clarified that a "relaxed" certification standard is no longer valid and that a nationwide class alleging various types of ADA architectural barriers (e.g., slopes, signage, door hardware) lacked commonality because the claims did not depend on a common contention capable of classwide resolution. The case was remanded for reconsideration of a narrower class definition.

Holdings

1. Plaintiffs have standing because they alleged concrete, particularized injuries (physical difficulty ambulating through non-compliant parking facilities) that are fairly traceable to Steak 'n Shake's policies and redressable by injunctive relief.
2. Plaintiffs failed to satisfy Rule 23(a)(1) numerosity and Rule 23(a)(2) commonality. The class definition was too broad and lacked sufficient evidence to support numerosity or commonality.

Questions Presented

1. Whether Plaintiffs have Article III standing to bring their ADA claims.
2. Whether Plaintiffs satisfied the requirements of Federal Rule of Civil Procedure 23(a) for class certification.

Disposition

reversed_and_remanded