Maya v. Forty Niners Stadium Management Company LLC

Background

Enrique Maya and Rick Maya sued Forty Niners Stadium Management Co., Forty Niners Football Co. LLC, Forty Niners SC Stadium Co., Landmark Event Staffing Services, Inc., and Allied Universal Security Services Universal Protection Service LLP. The opinion refers to the first three entities as Niners Management, 49ers LLC, and Stadium Company.

The complaint alleges that Enrique Maya has physical limitations from polio and uses a wheelchair when he needs to walk more than a few steps. At a December 10, 2023 football game at Levi’s Stadium, the family’s ticketed seats were seven steps from the concourse. Because Enrique could not use the stairs, Rick placed him in an unoccupied wheelchair-designated space on the concourse, although the family did not have a ticket for that space.

An usher and security staff told the family that Enrique could not use the wheelchair space without a ticket. Security suggested that he watch the game on a television in the concourse and threatened to remove the family if they did not move. After three uniformed Santa Clara City police officers arrived, a security staff member told Rick that he and his family would be ejected if Rick did not stop complaining. The family then used the assigned seats, where Enrique had to be carried down the stairs. The complaint alleges that he felt humiliated and later urinated on himself because he did not ask to be taken to the restroom.

The Mayas alleged six causes of action against all defendants: disability discrimination under Title III of the Americans with Disabilities Act, retaliation and interference under the ADA, violations of California’s Disabled Persons Act, retaliation and interference under that Act, violations of the Unruh Civil Rights Act, and retaliation and interference under that Act. They sought injunctive relief under the ADA and damages under the Disabled Persons Act and Unruh Act.

Motions and legal standard

Niners Management, 49ers LLC, and Stadium Company moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that the complaint failed to state valid claims. On such a motion, the court considers whether the complaint alleges enough facts to make liability a reasonable possibility, accepts factual allegations as true, and views the pleading in the plaintiffs’ favor. The Mayas separately moved to strike statements in the defendants’ motion.

Judicial notice

The court granted the defendants’ requests for judicial notice of versions of Levi’s Stadium’s ticket-information, accessible-services, and security-policy webpages. Judicial notice allowed the court to recognize the webpages’ existence and contents as of the listed dates. It did not allow the court to treat factual assertions on those webpages as true or infer that those versions were in effect during the events at issue or that the defendants followed them.

Disability-discrimination claims

For purposes of the motion, the parties did not dispute that Enrique qualified as a person with a disability under the ADA or that the defendants were private entities subject to Title III. The defendants instead disputed whether the Mayas adequately alleged discrimination.

The court found two plausible theories. First, the Mayas alleged that the defendants required wheelchair users to buy wheelchair-seat tickets in advance to receive a viewing experience comparable to that available to other spectators, while nondisabled guests could accept a ticket at the last minute. The court concluded that these allegations plausibly described a policy or practice denying disabled individuals full and equal enjoyment of the stadium’s goods, services, facilities, privileges, advantages, or accommodations.

Second, the Mayas alleged that the defendants failed to make a reasonable modification to their policies and practices. Rick repeatedly asked for an accessible seating option for Enrique, including use of an empty wheelchair space. The defendants allegedly offered only a television in the concourse and provided no other option after Rick said that alternative was unreasonable. The court explained that whether a modification is reasonable is a fact-specific question generally not suitable for resolution on a motion to dismiss. The Mayas did not need to establish at this stage that the defendants specifically had to provide the empty wheelchair seats; they plausibly alleged that the defendants had to offer some reasonable accommodation and did not do so.

Because the court found that the Mayas adequately pleaded an ADA violation, it also found that they adequately pleaded related claims under the Disabled Persons Act and Unruh Act.

Retaliation and interference claims

The ADA prohibits coercing, intimidating, threatening, or interfering with a person exercising or helping another person exercise ADA rights. The Mayas alleged that Rick engaged in protected activity by asserting Enrique’s rights and that the defendants responded with a threat of ejection made in the presence of police officers.

The court found those allegations sufficient to plausibly infer that the threat interfered with the Mayas’ efforts to obtain an accommodation. The court also recognized the defendants’ argument that the threat was made for nondiscriminatory reasons—because the Mayas occupied seats for which they had no tickets or refused to leave them. Whether the threat was instead a response to Rick’s advocacy was a factual issue that could not be resolved under Rule 12(b)(6). The court therefore found that the Mayas adequately pleaded retaliation or interference under the ADA and related claims under the Disabled Persons Act and Unruh Act.

Motion to strike and disposition

The Mayas moved to strike statements in the defendants’ motion that they characterized as false, misleading, unsupported, or outside the record. The court denied that motion because some statements involved matters of public record subject to judicial notice, while others were legal conclusions or facts on which the court did not rely.

The court denied the three defendants’ motion to dismiss and denied the Mayas’ motion to strike. The opinion did not resolve the ultimate merits of the claims; it held that the complaint could proceed past the pleading stage.