Langer v. Home Depot Product Authority, LLC

Background

Chris Langer brought two disability-discrimination claims against Home Depot Product Authority, LLC: one under the federal Americans with Disabilities Act and one under California’s Unruh Civil Rights Act. The claims arose from Home Depot’s alleged failure to provide closed captioning on at least one video on its website.

Home Depot moved under Federal Rule of Civil Procedure 12(e) for a more definite statement about Langer’s residency. Langer stated in his opposition that his county of residence was San Diego, although he spent significant amounts of time living in both the Central and Northern Districts. The court noted that Langer apparently had not included that information in his complaint.

The complaint alleged that Home Depot was a Georgia limited liability company, owned stores in California, and owned the website. It did not allege that Langer accessed the website in California or that he resided in California.

Legal standard

Rule 12(e) permits a court to require a more definite statement when a pleading is so vague or ambiguous that the opposing party cannot reasonably prepare a response. Such motions are generally disfavored because the federal rules require only a short and plain statement of the claim. They may be granted, however, when a complaint is so general that the nature of the claim or the parties’ relationship to it is unclear.

Discussion

The court explained that the Unruh Civil Rights Act applies only if Langer was a California resident or accessed Home Depot’s website while in California. The complaint did not allege facts, including Langer’s residency, showing where the alleged injury occurred or whether California law applied.

Because the missing residency information created uncertainty about the state-law claim, the court granted Home Depot’s motion for a more definite statement as to Langer’s residency.

Disposition

The court granted Home Depot’s motion for a more definite statement. It ordered Langer to file an amended complaint by December 4, 2020, and vacated the scheduled hearing because the matter could be resolved without oral argument.