Strojnik v. Resort at Indian Springs, LLC

Background

Peter Strojnik, representing himself, alleged that Resort at Indian Springs, LLC violated the Americans with Disabilities Act (ADA), the California Unruh Civil Rights Act, and the California Disabled Persons Act, and was negligent. The allegations concerned a hotel in Calistoga, California. Strojnik alleged that booking websites did not describe the hotel’s accessibility features in enough detail, did not make accessible-room reservations available in the same manner as other reservations, and disclosed architectural barriers. He alleged that he was deterred from visiting the hotel but intended to visit when it became fully compliant.

Request for Judicial Notice

The Resort asked the court to take judicial notice of a Google Maps printout showing the distance and directions from Strojnik’s address to the hotel, search results concerning other cases Strojnik had filed while representing himself, an Arizona State Bar complaint, and an Arizona State Bar judgment of disbarment. The court denied the request because the documents were not relevant to deciding the motion to dismiss. The court stated that the Resort could renew the request if the documents became relevant to other issues.

Motion to Dismiss: ADA Claims

The Resort argued that Strojnik lacked Article III standing, meaning the constitutional basis to bring the claim in federal court. For an ADA claim seeking an order requiring future compliance, the court explained that a plaintiff must allege a concrete injury connected to the challenged conduct and a real and immediate threat of repeated injury.

The court held that Strojnik had not adequately explained how the alleged barriers affected his full and equal use of the hotel in light of his particular mobility limitations. His complaint stated that he walked with difficulty and pain and needed accessible mobility features, but it did not provide enough detail about his limitations or connect them to the specific alleged barriers. The court also held that his statements that he was deterred from visiting and would visit after the hotel became compliant were not plausible without those additional details. The court granted dismissal of the ADA claim with leave to amend on both grounds.

Motion to Dismiss: State Claims

The court granted dismissal of the Unruh Act and Disabled Persons Act claims with leave to amend. It concluded that Strojnik had not pleaded facts showing that he was a person within California’s jurisdiction for purposes of the Unruh Act or that the Disabled Persons Act protected him for injuries occurring outside California. The opinion noted that Strojnik resided in Arizona and apparently accessed the Resort’s website from Arizona, while also observing that the record contained conflicting suggestions about whether he had visited the hotel.

The court dismissed the negligence claim without prejudice to Strojnik’s refiling it in state court or including it in an amended complaint in the federal case. Because the court dismissed the ADA claim, it found that there was then no basis for supplemental jurisdiction, which is federal jurisdiction over related state-law claims. The court stated that the Resort could renew its arguments against the negligence claim if Strojnik included it in an amended complaint.

Plaintiff’s Motion for Partial Summary Judgment

Strojnik sought partial summary judgment on his ADA and Unruh Act claims. The court denied the motion. It found the motion premature because the court’s dismissal order allowed Strojnik to amend, so the pleadings were not yet settled. The court also found that the Resort should be allowed to conduct discovery before responding to summary judgment.

The court further concluded that Strojnik’s submissions did not establish entitlement to judgment as a matter of law. More factual development was needed to evaluate the hotel’s reservation information and whether architectural-barrier removal was readily achievable, a fact-specific question under the ADA. The court required Strojnik to obtain permission before filing another summary-judgment motion.

Disposition

The court granted the Resort’s motion to dismiss the ADA, Unruh Act, and Disabled Persons Act claims with leave to amend. It dismissed the negligence claim without prejudice to refiling in state court or in an amended federal complaint. It denied the Resort’s request for judicial notice and denied Strojnik’s motion for partial summary judgment. The order permitted an amended complaint by January 15, 2020, if Strojnik could address the identified deficiencies while complying with the rule governing factual and legal filings.