Daniel Mellenthin v. Rock Road Equities, LLC

Summary

The United States District Court for the Eastern District of Missouri grants Daniel Mellenthin’s motion for default judgment against Rock Road Equities, LLC in an action alleging violations of the Americans with Disabilities Act. The court orders Rock Road to remove the specified architectural and restroom-accessibility barriers where removal is readily achievable, but declines to order closure of the property. The order also requires Mellenthin to serve the order and judgment on Rock Road and file proof of service.

Holdings

1. A default judgment may be entered after the Clerk has entered default when the complaint's well-pleaded factual allegations, taken as true, establish a legitimate cause of action; default does not admit legal conclusions.
2. The well-pleaded allegations that Rock Road's property contained specified architectural and accessibility barriers established an ADA violation sufficient to support injunctive relief under 42 U.S.C. § 12188(a).
3. Rock Road must remove the specified barriers only where removal is readily achievable, meaning easily accomplishable and capable of being carried out without much difficulty or expense.
4. The court declined to order closure of the property pending removal of the alleged barriers.

Questions Presented

1. Whether the court should enter default judgment after Rock Road failed to plead or otherwise defend.
2. Whether Mellenthin's well-pleaded allegations established an ADA violation warranting injunctive relief.
3. Whether the requested injunction should require removal of the alleged barriers only where removal is readily achievable.
4. Whether the court should order closure of the property until the barriers were removed.

Disposition

other