Castillo-Antonio v. Mata

Background

Jose Daniel Castillo-Antonio sued El Pueblo Panaderia #1 and its owners for alleged violations of the Americans with Disabilities Act (ADA), California disability and civil rights laws, and the California Unruh Act. The motion addressed the ADA and Unruh Act claims. Castillo-Antonio alleged that he uses a walker and could not fully access the grocery store because of three architectural barriers: a partially blocked main entrance, a service counter that did not meet statutory width and height requirements, and aisles that did not meet statutory width requirements.

Castillo-Antonio moved for default judgment, which is a judgment entered when a defendant does not defend the case. He requested an accessibility injunction, attorney's fees and costs, and statutory damages under the Unruh Act.

Court's analysis

The court found that it had personal jurisdiction over the defendants, meaning authority over them, and subject matter jurisdiction, meaning authority to decide the type of dispute. It also found that the defendants were properly served and that Castillo-Antonio had standing to sue. The court concluded that the relevant factors favored default judgment because the complaint adequately alleged ADA and implementing-regulation violations, an ADA violation automatically constitutes an Unruh Act violation under California Civil Code section 51(f), and the defendants knew about the lawsuit and had communicated with Castillo-Antonio about it.

The court held that the ADA permits injunctive relief and that both the ADA and Unruh Act permit reasonable attorney's fees and costs. It ordered the defendants to provide an ADA-compliant main entrance, service counter, and aisles, subject to the ADA's “readily achievable” standard. It awarded the requested $2,835 in attorney's fees and $687.50 in costs.

The court partially denied the request for Unruh Act statutory damages. Castillo-Antonio alleged four visits to the store and sought $12,000 for three of them. The court determined that it had discretion to award damages for fewer visits and that a plaintiff should not automatically accumulate statutory damages by repeatedly visiting a business before filing suit without communicating the access concerns to the business. The court noted that Castillo-Antonio visited four times within 10 months, did not live or work close to the store, had not shown that he raised the barriers with store employees or owners, and had not shown that he had reason to believe the barriers would be removed after any earlier visit. The court also noted that he had served as a plaintiff in at least 172 ADA cases in the Northern District of California.

Disposition

Default judgment was entered against the defendants on the ADA and Unruh Act claims. The court awarded $4,000 in statutory damages for the first visit, $2,835 in attorney's fees, and $687.50 in costs, for total fees and costs of $3,522.50. The court also entered the described injunction. In Castillo-Antonio v. Mata, Judge Vince Chhabria therefore granted in part and denied in part the motion for default judgment.