Scott Crawford v. Uber Technologies, Inc.

Background

The defendants filed a motion in limine, which is a pretrial request to exclude particular evidence. They sought to bar the plaintiffs from introducing evidence relating to or supporting a request that the defendants take steps to enable or provide wheelchair-accessible vehicle trips to people other than the plaintiffs.

The motion concerned claims under the Americans with Disabilities Act (ADA). The opinion states that the plaintiffs sought wheelchair-accessible vehicle service in New Orleans and Jackson. The defendants argued that this requested relief required class certification, which the plaintiffs had not sought or obtained. The opinion also refers to a second defense argument, but the provided text does not fully reproduce that argument.

Court’s Analysis

The court explained that the ADA expressly permits injunctive relief involving policy changes and facility alterations. Such relief may benefit people beyond the individual plaintiff. The court cited decisions in which injunctions required changes benefiting other people with disabilities.

The court held that plaintiffs may seek an injunction benefiting more than themselves without seeking or obtaining class certification. It also stated that the court would decide whether the requested relief was a reasonable modification under the ADA. The possibility that relief benefiting a large group could make proving reasonableness more difficult concerned the merits of the case, not the admissibility of evidence.

Ruling

Judge Richard Seeborg denied the defendants’ motion in limine. The order did not decide whether the requested wheelchair-accessible vehicle service would ultimately be required, whether the requested modification was reasonable, or whether the plaintiffs would prevail on the merits.