Renowitzky v. Stonebrae Club Partners, LLC

Background

Arthur Renowitzky uses a wheelchair for mobility. In 2017, he attended the Ellie Mae Classic golf tournament at TPC Stonebrae, a private country club in Hayward, California. He alleged violations of federal and state law based on three sets of circumstances: an alleged lack of accessible portable restrooms on the golf course; inaccessible portions of the viewing platform and concession area at the 16th hole; and the denial of requests to use an accessible clubhouse bathroom and later an accessible portable restroom. He alleged that the requested facilities were in areas restricted to club members or people with “VIP” access during the tournament.

Stonebrae Club Partners, LLC owns and operates the country club. PGA Tour, Inc. operates the Korn Ferry Tour, which includes the Ellie Mae Classic. The parties filed cross-motions for summary judgment, a procedure used to resolve claims when the undisputed facts show that one side is entitled to judgment as a matter of law.

ADA claims and mootness

The federal claims in the operative First Amended Complaint were brought exclusively under the Americans with Disabilities Act, or ADA. The court noted that a private plaintiff may obtain injunctive relief under the ADA but not damages. The defendants argued that the ADA claims were moot because the Ellie Mae Classic had been discontinued and would never be held again at Stonebrae or elsewhere.

A claim is moot when there is no longer a live dispute for which a court can grant effective relief. The court concluded that Renowitzky’s claims concerned temporary conditions created for the 2017 tournament and employee responses to two accommodation requests during that event. Because the tournament had been discontinued, and because the alleged conditions were not reasonably certain to recur in the same form, the court held that the ADA claims were moot.

The court rejected Renowitzky’s arguments that Stonebrae’s continued operation, its availability for social or corporate events, the possibility of another tournament at Stonebrae, or the possibility that PGA Tour might hold tournaments elsewhere in the Bay Area kept the claims live. The court found that those events would not necessarily recreate the conditions alleged in the complaint and that injunctive relief was unavailable for hypothetical, unpleaded, and speculative future violations at different courses or tournaments.

State-law claims

The defendants also argued that the state-law claims should fail on their merits. The court declined to decide that issue. Instead, after finding the ADA claims moot, it exercised its discretion not to retain supplemental jurisdiction—the authority to hear related state-law claims alongside federal claims. The court determined that state courts should decide whether the factual record supported state-law damages claims and dismissed the state-law claims without prejudice to refiling in state court.

Disposition

The court granted defendants’ motion for summary judgment as to the ADA claims because the undisputed facts showed that those claims were moot. It dismissed the state-law claims without prejudice to refiling in state court. It denied Renowitzky’s motion without prejudice to any determination of the merits of his state-law claims in state court. The court therefore did not decide the merits of the ADA claims or the state-law claims.

Judge

The order was signed by Richard Seeborg, United States District Judge, on January 12, 2021.