Strojnik v. Resort at Indian Springs, LLC
- Susan Van Keulen
- 5:19-cv-04616
- U.S. District Court · Northern District of California
- 7
In Strojnik v. Resort at Indian Springs, Judge Van Keulen denied the hotel’s motion to dismiss disability-law and negligence claims, allowing the case to proceed.
Peter Strojnik’s ADA, Unruh Act, DPA, and negligence claims remained pending against Resort at Indian Springs, LLC. The defendant was required to answer the amended complaint within 21 days, and the case was set to continue toward scheduling and case management.
What happened
In Strojnik v. Resort at Indian Springs, LLC, Peter Strojnik, who represented himself, alleged that the hotel violated federal and California disability-access laws and was negligent. He alleged that booking websites did not adequately describe accessibility features, that accessible rooms could not be reserved in the same way as other rooms, and that the hotel had physical access barriers.
The hotel asked the court to dismiss all claims, arguing that the court lacked authority to hear them and that the amended complaint did not state valid claims. The court found that Strojnik’s amended allegations connected the barriers to his mobility limitations, showed an intent to visit the hotel, established that he had stayed there, and plausibly supported his negligence claim.
Judge Susan Van Keulen denied the motion to dismiss the amended complaint. The federal disability claim, the California Unruh Act and Disabled Persons Act claims, and the negligence claim therefore remained in the case, and the court ordered the hotel to answer within 21 days.
The detailed version
- Strojnik v. Resort at Indian Springs, LLC · No. 5:19-cv-04616
- Susan Van Keulen
- June 25, 2020
Background
Peter Strojnik represented himself and 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 (DPA), and was liable for negligence. He alleged that he has medical conditions that substantially limit major life activities, walks with difficulty and pain, and requires accessible features at public accommodations.
Strojnik alleged that, while planning a trip to California Wine Country, he found that the hotel’s first-party and third-party booking websites did not describe accessibility features in enough detail for him to determine whether the hotel or its rooms met his needs. He also alleged that third-party booking websites did not make accessible-room reservations available in the same manner as reservations for people who do not need accessible rooms. He alleged that he stayed at the hotel on April 17, 2019, and personally encountered accessibility barriers that interfered with his full and equal enjoyment of the hotel.
The court had previously dismissed his original complaint with permission to amend. It found that the original ADA allegations did not adequately connect the alleged barriers to his disability or show continuing adverse effects. It also dismissed the Unruh Act and DPA claims because the complaint did not show that Strojnik was a person within California’s jurisdiction for purposes of those claims. The negligence claim was dismissed because, after dismissal of the ADA claim, the court had no basis for supplemental jurisdiction over it.
Defendant’s Motion
Resort at Indian Springs moved to dismiss all claims in the First Amended Complaint under Federal Rule of Civil Procedure 12(b)(1), which addresses lack of subject-matter jurisdiction, and Rule 12(b)(6), which addresses failure to state a claim. The court treated the motion as suitable for decision without oral argument.
ADA Claim
The court concluded that the First Amended Complaint corrected the defects identified in the original complaint. Strojnik described his medical conditions in greater detail and more specifically identified the barriers and how they affected his limited mobility. Although some statements accompanying photographs remained conclusory, the court found that they were sufficient when read together with the more detailed allegations.
The court also found that the amended complaint addressed Strojnik’s intent to visit the hotel. He alleged frequent past and planned future visits to Napa, that he stayed near the hotel, and that he would stay at the hotel but for the barriers. The court therefore denied the motion to dismiss the ADA claim.
Unruh Act and DPA Claims
The court found that Strojnik corrected the prior pleading problem by alleging that he stayed at the hotel on April 17, 2019. The court also rejected the request to decline supplemental jurisdiction, which is the court’s authority to hear related state-law claims alongside a federal claim. The state-law claims shared a common set of facts with the ADA claim, did not predominate over it, and retaining them served economy, convenience, and fairness. The court therefore denied the motion to dismiss the Unruh Act and DPA claims.
Negligence Claim
Because the ADA claim remained in the case, the court found a basis for supplemental jurisdiction over the negligence claim. The court also found that the amended complaint plausibly alleged a negligence claim, even if it were understood to rely on a negligence-per-se theory. The court stated that Strojnik plausibly alleged that the hotel violated a regulation, that he was injured by that violation, that the ADA and DPA were intended to protect disabled people, and that he is disabled. The court therefore denied the motion to dismiss the negligence claim.
Disposition and Next Steps
The court denied the defendant’s motion to dismiss. It ordered the defendant to answer the First Amended Complaint within 21 days. It also ordered the parties to file a joint proposed schedule within 30 days and scheduled a case-management conference for November 10, 2020.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.