Langer v. Home Depot Product Authority, LLC

Background

Chris Langer sued Home Depot Product Authority, LLC, under the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. Langer alleged that, in July 2020, he tried to watch a Home Depot website video titled “How to Use and Maintain An Evaporated Cooler,” but the video lacked closed captioning. The opinion states that Langer has Delayed Endolymphatic Hydrops, which caused permanent partial hearing loss, and that he uses closed captioning to understand online audio content. His complaint sought injunctive relief under the ADA and damages under the Unruh Act.

Home Depot moved for summary judgment. It submitted a declaration stating that the captioning problem had resulted from an issue with the YouTube platform, which hosted the video, and that Home Depot had implemented a workaround after learning about the lawsuit. The declaration also stated that Home Depot had a preexisting policy of captioning its videos, required vendor videos to be captioned, continued reviewing and captioning videos, and would not knowingly remove captions or abandon captioning. Home Depot also stated that it was unaware of other active litigation complaints alleging a lack of closed captioning on its website videos.

ADA Claim

Summary judgment is appropriate when the evidence shows no genuine dispute about a material fact and the moving party is entitled to judgment as a matter of law. In an ADA case seeking injunctive relief, a defendant may make the case moot by voluntarily correcting the challenged condition if the problem is not reasonably likely to happen again. A case is moot when the dispute is no longer live or the parties no longer have a legally recognized interest in the outcome.

Langer did not dispute that Home Depot had corrected the captioning problem with the video identified in the complaint. He argued that the correction was based on a policy that Home Depot could ignore or rescind and that captioning required continuing labor and expense. The court found that Langer had not presented evidence that Home Depot had posted other uncaptioned videos, and that he did not dispute Home Depot’s evidence that its captioning policy predated his complaint. The court found his concern that Home Depot might later remove captions or abandon its policy speculative and unsupported by evidence.

The court held that Home Depot had met its burden to show that Langer’s ADA claim was moot. It granted Home Depot’s motion for summary judgment on the ADA claim based on mootness and did not address Home Depot’s other arguments concerning that claim.

Unruh Act Claim

The Unruh Act claim was a state-law claim. The court explained that a federal district court may decline supplemental jurisdiction—the authority to hear related state-law claims—when it has dismissed all claims over which it had original federal jurisdiction. The court found that Langer’s ADA claim was the only claim providing original federal jurisdiction. Because the federal claim was moot, and because Langer said his Unruh Act claim was based exclusively on the alleged ADA violation, the court declined supplemental jurisdiction over the Unruh Act claim.

The court dismissed the Unruh Act claim without prejudice. The order therefore granted the motion for summary judgment on the ADA claim and separately declined supplemental jurisdiction over, and dismissed without prejudice, the Unruh Act claim.