Gomez v. Vintage Wine Estates, Inc.
- Vince Chhabria
- 3:22-cv-01610
- U.S. District Court · Northern District of California
- 2
In Gomez v. Vintage Wine Estates, Judge Chhabria lifted the show-cause order, kept the claims alive for now, and required a status report.
Andres Gomez and Vintage Wine Estates, Inc.; the ADA claim was not dismissed for lack of subject-matter jurisdiction at that time, and the Unruh Act claim was not dismissed on the exceptional-circumstances ground discussed in the order.
What happened
In Gomez v. Vintage Wine Estates, Inc., Andres Gomez alleged that the defendant’s website was inaccessible and asserted claims under the Americans with Disabilities Act and California’s Unruh Civil Rights Act.
The court held that the circumstances did not justify dismissing the Unruh Act claim because the alleged accessibility problem involved a website, not a construction-related barrier. It also found no current basis to dismiss the Americans with Disabilities Act claim for lack of jurisdiction and said jurisdictional discovery did not appear worthwhile. The court was skeptical that the complaint adequately stated an Americans with Disabilities Act claim, however, because it did not explain how the website’s problems prevented Gomez from visiting a physical location or accessing goods or services.
Judge Vince Chhabria lifted the order to show cause and ordered a status report by September 28, 2022. The defendant could request jurisdictional discovery if it could identify a basis for doing so.
The detailed version
- Gomez v. Vintage Wine Estates, Inc. · No. 3:22-cv-01610
- Vince Chhabria
- June 29, 2022
Background
Andres Gomez brought claims against Vintage Wine Estates, Inc., alleging that its website was inaccessible. The opinion addresses an order to show cause and discusses claims under the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act.
Unruh Act claim
The court explained that when a frequent litigant brings an Unruh Act claim in federal court together with an ADA claim, exceptional circumstances may sometimes justify dismissing the Unruh Act claim. But the court stated that this exception applies only when the plaintiff asserts a construction-related accessibility claim. Because Gomez’s claim concerned website accessibility rather than a construction-related accessibility condition, the court concluded that exceptional circumstances did not justify dismissing the Unruh Act claim under 28 U.S.C. § 1367(c)(4).
Jurisdiction and ADA claim
The court stated that the threshold for establishing standing to seek an injunction in an ADA website-accessibility case is low. It therefore found no basis at that time to dismiss the ADA claim for lack of subject-matter jurisdiction. The court also stated that jurisdictional discovery did not appear likely to be useful, while allowing Vintage Wine Estates, Inc. to request that discovery if it could articulate a basis for it.
The court expressed skepticism that the complaint stated an ADA claim because it did not explain how the website’s alleged deficiencies prevented Gomez from visiting the defendant’s physical location or accessing its goods or services. The opinion did not resolve whether the ADA claim ultimately succeeds.
Order
Judge Vince Chhabria lifted the order to show cause. The court ordered a status report by September 28, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.