Sepulveda v. Alomari

Summary

The United States District Court for the Northern District of California denied Defendants’ motion for summary judgment and granted Plaintiff’s motion for partial summary judgment in an action concerning alleged barriers to accessibility at Mi Ranchito Market. The court found genuine disputes regarding Plaintiff’s standing to seek injunctive relief and held that Plaintiff established his disability, encountered the alleged barriers, and that the barriers continued to exist. The court did not grant summary judgment on the ultimate availability of injunctive relief or damages because the readily achievable removal issue remained unresolved.

Holdings

1. A Title III ADA plaintiff may establish standing for injunctive relief by presenting evidence that he is currently deterred from visiting a place of public accommodation because of an accessibility barrier or was previously deterred and intends to return where he is likely to encounter the barrier. Plaintiff's evidence concerning his ongoing medical care and ties to Oakland created a genuine dispute regarding his intent to revisit the market.
2. Defendants were not entitled to summary judgment because genuine disputes of material fact existed regarding Plaintiff's intention to revisit Mi Ranchito Market.
3. Plaintiff was entitled to partial summary judgment establishing that the alleged barriers existed on the dates he visited Mi Ranchito Market, that he encountered them, and that the barriers continued to exist.
4. Plaintiff was not entitled at this stage to summary judgment establishing his complete causes of action or entitlement to injunctive relief and damages because he had not shown that removal of the barriers was readily achievable.

Questions Presented

1. Whether Plaintiff had standing to seek injunctive relief under Title III of the ADA despite moving approximately 60 miles from the market.
2. Whether genuine disputes of material fact concerning Plaintiff's deterrence and intent to revisit the market precluded summary judgment for Defendants.
3. Whether Plaintiff established on partial summary judgment that the alleged accessibility barriers existed on the visit dates, that he encountered them, and that they continued to exist.
4. Whether Plaintiff was entitled to summary judgment establishing his complete ADA claims or entitlement to injunctive relief and damages.

Disposition

other