Whitaker v. Starbucks Corporation

Background

Brian Whitaker sued Starbucks Corporation and Does 1–10. He alleged two claims: discrimination under the Americans with Disabilities Act of 1990 and violation of California’s Unruh Civil Rights Act. The claims concerned alleged architectural barriers at a Starbucks location, including a lack of accessible dining surfaces.

Starbucks moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(1), which concerns certain jurisdictional defects, and Rule 12(b)(6), which concerns whether a complaint states a legally sufficient claim.

Court’s Analysis

The court applied the rule that a complaint must include enough factual allegations to make the requested relief plausible, rather than merely possible. It concluded that the complaint, although brief, met the federal notice-pleading requirements for both the Americans with Disabilities Act claim and the Unruh Act claim.

For an Americans with Disabilities Act claim based on architectural barriers at a place of public accommodation, a plaintiff must identify the allegedly noncompliant features. The court found that Whitaker satisfied this requirement by alleging that the Starbucks location lacked accessible dining surfaces.

The court also noted that General Order 56 and the operative initial case-management scheduling order required the parties to inspect the premises. The court stated that this process addressed Starbucks’s concerns about the specific obstacles at the location. The court further observed that unpublished judicial decisions cited by Starbucks were persuasive but not binding on the court.

Disposition

The court denied Starbucks’s motion to dismiss. The order did not dismiss Whitaker’s two claims. It directed the defendants to answer the complaint within 21 days and scheduled a case-management conference for March 16, 2020. The order terminated Docket Number 10.

Classification

This is a procedural order because the court ruled on a motion to dismiss under Rules 12(b)(1) and 12(b)(6), deciding only that the complaint could proceed at this stage rather than deciding the ultimate merits of the claims.