Gastelum v. Best Buy, Inc.

Summary

The document is a magistrate judge’s findings and recommendations concerning cross-motions for summary judgment in an ADA Title III accessibility case. The court recommends granting Best Buy’s motion and denying Fernando Gastelum’s motion because he failed to establish an injury in fact for Article III standing; it alternatively concludes that his evidence was insufficient to prove the alleged accessibility violations.

Holdings

1. An ADA plaintiff seeking injunctive relief must provide admissible evidence and specific facts showing that an alleged accessibility barrier affected the plaintiff's full and equal enjoyment of the facility because of the plaintiff's particular disability. Gastelum failed to make that showing because he did not establish that he used a wheelchair at the store or otherwise explain how the alleged barriers affected the loss of his leg.
2. Gastelum was not entitled to summary judgment because his photographs, declaration, and legal conclusions did not objectively establish violations of the ADA Accessibility Guidelines.
3. Best Buy's motion for summary judgment should be granted, and Gastelum's motion for summary judgment should be denied.

Questions Presented

1. Whether Gastelum established Article III injury-in-fact standing to seek injunctive relief under Title III of the ADA.
2. Whether Gastelum's evidence established violations of the ADA Accessibility Guidelines concerning accessible-route width, bathroom-door operating force, or service-counter accessibility.
3. Whether Best Buy's motion for summary judgment should be granted and Gastelum's cross-motion denied.

Disposition

other