Strojnik v. Starbucks Corporation

Background

Peter Strojnik alleged in an amended complaint that Starbucks discriminated against customers with disabilities in violation of the Americans with Disabilities Act, California’s Unruh Civil Rights Act, the Disabled Persons Act, the Unfair Competition Law, the Consumer Legal Remedies Act, and related claims for injunctive relief, malice, and oppression.

Strojnik originally filed the case in California state court. Starbucks removed it to federal court and later moved to dismiss, arguing that Strojnik’s amended complaint violated a prefiling order governing his litigation in the Northern District of California. The order prohibited him from filing a civil action challenging access to public accommodations by disabled people without first obtaining certification from the court’s general duty judge. Strojnik also moved to strike Starbucks’ motion to dismiss.

Reasons for Dismissal

The court held that the amended complaint clearly challenged access to public accommodations by disabled people. It was undisputed that Strojnik had not obtained the required certification before filing it. The court rejected Strojnik’s argument that the order did not apply because Starbucks had removed the case from state court. The court explained that filing a complaint commences a civil action and that the amended complaint independently fell within the prefiling order.

The court also addressed Starbucks’ argument that Strojnik had not properly served the summons. The court stated that the parties appeared to agree that Strojnik served the initial complaint but not the summons, contrary to California requirements. It rejected Strojnik’s argument that Starbucks waived this defense through removal and other procedural actions, concluding that inadequate service provided another basis for dismissal.

Other Motions and Disposition

The court denied Strojnik’s motion to strike. It explained that a motion to strike under Federal Rule of Civil Procedure 12(f) applies to pleadings, not motions, but it treated Strojnik’s filing as another argument against dismissal. The court rejected the argument that General Order 56 barred Starbucks from seeking dismissal. It also stated that, even if the order applied, the court had discretion to allow Starbucks’ motion.

The court granted Starbucks’ motion to dismiss, denied Starbucks’ motion for sanctions, and denied Strojnik’s motion to strike. Because the action was dismissed, the court denied Starbucks’ application to stay the action as moot. The opinion does not state that the dismissal was with or without prejudice.