Johnson v. San Carlos Inn
- Sallie Kim
- 3:19-cv-00061
- U.S. District Court · Northern District of California
- 3
In Johnson v. San Carlos Inn, Judge Kim granted judgment on the pleadings after finding the disability claim moot and dismissed the state-law claim.
Scott Johnson’s federal disability claim was found moot and the motion for judgment on the pleadings was granted on that claim. His state-law claim was dismissed without prejudice to refiling in state court. San Carlos Inn prevailed on the federal claim.
What happened
Johnson v. San Carlos Inn involved Scott Johnson’s claim that the motel had barriers affecting accessible rooms, online reservations, and parking. San Carlos Inn argued that the barriers had been corrected or did not exist and that Johnson lacked standing.
The court relied on evidence that accessible rooms and online reservations were available and that the parking areas complied with accessibility requirements. Because Title III of the Americans with Disabilities Act allows a private plaintiff to seek only an order requiring removal of barriers, the court found Johnson’s disability claim moot and granted the motel’s motion for judgment on the pleadings on that claim.
The court declined to hear Johnson’s state-law claim and dismissed it without prejudice to refiling in state court. Judge Sallie Kim ordered the clerk to close the file and said a separate judgment would issue.
The detailed version
- Johnson v. San Carlos Inn · No. 3:19-cv-00061
- Sallie Kim
- Jan. 22, 2020
Background
Scott Johnson alleged that San Carlos Inn violated Title III of the Americans with Disabilities Act by failing to provide enough accessible rooms in different sleeping-accommodation categories, by not allowing customers to reserve accessible rooms online, and by failing to provide compliant van-accessible parking and a level access aisle. The defendant moved for judgment on the pleadings, arguing that the requested injunctive relief was moot because the alleged barriers had been corrected or did not exist, and that Johnson lacked standing.
The court noted that Johnson’s opposition was filed late and did not address factual issues raised by the motion. The court gave him another opportunity to respond on the merits, but he did not file supplemental opposition by the deadline. The court therefore addressed the motion.
Court’s analysis
The court explained that a private plaintiff bringing a Title III disability-discrimination claim may obtain only injunctive relief. To maintain such a claim, the plaintiff must have a continuing or likely future injury. Removing an architectural barrier before final judgment can therefore make the claim moot.
San Carlos Inn submitted evidence that it had accessible rooms complying with the Americans with Disabilities Act and that customers could make online reservations for those rooms. It also submitted a survey from Larry Wood, a state-licensed Certified Access Specialist, who reported that the motel had the required number of van-accessible parking spaces, that the parking stalls and access aisle were level with each other, and that there were no slopes greater than 2.1 percent. Wood concluded that the architectural barriers identified in Johnson’s complaint had been corrected and were fully compliant.
Disposition
The court found Johnson’s Americans with Disabilities Act claim moot and granted San Carlos Inn’s motion for judgment on the pleadings on that claim. The court declined to exercise supplemental jurisdiction, meaning jurisdiction over related state-law claims, and dismissed Johnson’s state-law claim without prejudice to refiling it in state court. The court ordered that a separate judgment issue and that the clerk close the file.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.