Strojnik v. Woodside Hotel Group LTD

Background

Peter Strojnik, representing himself, sued Woodside Hotel Group, LTD, doing business as Monterey Plaza Hotel & Spa. He alleged that he personally stayed at the hotel on or about September 26–27, 2019, encountered accessibility barriers involving areas including the valet, concierge counter, check-in counter, staircase, and seating areas, and was denied full and equal access to the hotel. He brought claims under the Americans with Disabilities Act, the California Unruh Civil Rights Act, the California Disabled Persons Act, and negligence. He also alleged that he intended to visit the hotel again after its alleged accessibility problems were corrected.

Woodside moved to dismiss the First Amended Complaint under Federal Rule of Civil Procedure 12(b)(1), which concerns the court’s subject-matter jurisdiction, and Rule 12(b)(6), which tests whether a complaint states a legally sufficient claim.

Court’s analysis

The court focused on whether Strojnik had Article III standing. Standing requires an injury in fact, a connection between that injury and the defendant’s conduct, and the possibility that a court decision can remedy the injury. For an accessibility claim under the ADA, the court explained that a plaintiff must connect a particular barrier to the plaintiff’s particular disability and show that the barrier interfered with full and equal enjoyment of the facility.

The court found that the First Amended Complaint identified some barriers and included photographs, but did not adequately explain how the specific features shown in the photographs were inaccessible to Strojnik because of his specific disabilities. The court also found that many of his allegations described generalized medical conditions without meaningfully explaining how those conditions affected his encounter with each barrier. As one example, the court said that Strojnik alleged that an unmarked passenger-loading zone made him walk farther, but did not allege that he arrived in or needed a wheelchair during the visit. The court further considered a medical examination and surveillance videos submitted by Woodside and found that Strojnik had not provided evidence sufficient to establish that he was disabled during his hotel visit in a way that related to the alleged barriers.

Because Strojnik had not sufficiently alleged an injury in fact, the court did not address whether he adequately pleaded an intent to return. The court also found that he had not adequately pleaded standing under a deterrence theory because he did not sufficiently explain how the alleged barriers related to his disabilities or affected his access to the hotel.

Disposition

The court dismissed Strojnik’s ADA claim for lack of subject-matter jurisdiction. Because the court lacked jurisdiction over the sole federal claim, it also dismissed the Unruh Act, California Disabled Persons Act, and negligence claims because it could not exercise supplemental jurisdiction over them.

The court granted Woodside’s motion to dismiss with leave to amend. In its discussion, the court granted Strojnik 30 days to amend, but the final order required him to file an amended complaint no later than 14 days and to file it with the previously imposed $20,000 costs bond. The final order stated that failure to timely post the bond and amend the First Amended Complaint would result in dismissal with prejudice, and that an improperly pleaded amended complaint would receive no additional opportunity to amend.

The court also granted the parties’ requests for judicial notice and granted Woodside’s request to consider three surveillance videos for the limited purpose of addressing the factual challenge to subject-matter jurisdiction. It struck pages 6–8 of Woodside’s evidentiary objections for violating page limits, sustained objections 1–5 as irrelevant, and overruled objections 6–8.