Whitaker v. Chanel, Inc.

Background

Brian Whitaker sued Chanel, Inc. under the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. He alleged that, during a November 2021 visit to Chanel’s store in Santa Clara, California, he encountered a lounge table that lacked sufficient knee or toe clearance and was too low for him to sit at while his girlfriend shopped.

Chanel moved to dismiss for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1), arguing that Whitaker lacked standing and that his ADA claim was moot. Whitaker separately sought administrative relief requiring Chanel to provide dates for a joint site inspection.

ADA Standing

The court held that Whitaker had not adequately pleaded an injury-in-fact, which is a concrete and particularized injury required for standing in federal court. The court rejected Whitaker’s argument that the ADA standards themselves established a violation because the complaint did not allege facts showing that the lounge table was a dining surface, work surface, or another category covered by a specific ADA standard.

The court also rejected Whitaker’s reliance on the ADA’s general protection against denying people with disabilities the full and equal enjoyment of a public accommodation. Although Whitaker alleged that the table lacked knee or toe clearance, was too low, and could not be used by him, he did not explain whether nondisabled customers could place their knees and toes under the table, sit at it, or otherwise use it in a way that he could not. The court therefore found that he had not pleaded facts showing that he was denied full and equal enjoyment of the table.

The court separately held that Whitaker had not shown a real and immediate threat of repeated injury, as required for an ADA plaintiff seeking an injunction. The court considered the distance between Whitaker’s home and the store, his lack of alleged visits other than the November 2021 visit, his lack of specific plans to return, and his lack of alleged ties to the area. The court concluded that his general statement that he intended to return and was deterred by the alleged barriers was insufficient because he had not plausibly alleged an intent to return.

Mootness

Chanel argued that the ADA claim was moot because the only coffee table in the store had been removed and would not be replaced. The court denied the motion to dismiss on mootness grounds. It found that Chanel had not met the demanding burden required to show that the alleged violation could not reasonably recur, because the evidence did not establish that removing the table could not later be reversed.

The court nevertheless dismissed the ADA claim because Whitaker lacked standing. The dismissal was with leave to amend, and the court found that amendment would not be futile.

Unruh Act Claim

After dismissing the only federal claim, the court declined to exercise supplemental jurisdiction over Whitaker’s related California Unruh Act claim. Supplemental jurisdiction is a federal court’s authority to hear a related state-law claim in the same case. The court concluded that considerations including comity—the appropriate respect for state courts and state law—supported declining jurisdiction. The Unruh Act claim was dismissed without prejudice.

Administrative Relief and Disposition

The court denied Whitaker’s motion for administrative relief without prejudice to refiling if needed after a further responsive pleading was filed.

In the final disposition, the court denied Chanel’s motion to dismiss for mootness, granted Chanel’s motion to dismiss for lack of standing under Rule 12(b)(1), dismissed the ADA claim with leave to amend, and dismissed the Unruh Act claim without prejudice. Whitaker was permitted to file an amended complaint by May 5, 2022, without adding new claims or parties absent permission or agreement. Judge Susan Van Keulen signed the order.