Chapman v. Inn at Schoolhouse Creek in Little River

Background

Byron Chapman filed a disability-access action concerning architectural barriers he says he encountered during an August 25–27, 2021 stay at The Inn at Schoolhouse Creek. He named The Inn at Schoolhouse Creek in Little River, LR Schoolhouse LLC, and Kila Schoolhouse LLC as defendants. Only LR Schoolhouse had been served or appeared.

Chapman asserted claims under Title III of the Americans with Disabilities Act and under California Civil Code sections 51, 54, 54.1, and 54.3. LR Schoolhouse moved to dismiss under Federal Rules of Civil Procedure 12(b)(1), which concerns the court’s jurisdiction, and 12(b)(6), which concerns whether a complaint states a legally sufficient claim.

Standing under the Americans with Disabilities Act

The court held that Chapman adequately alleged the constitutional requirements for standing. For a private Title III lawsuit seeking an order requiring accessibility changes, a plaintiff must show an actual injury and a sufficient likelihood of future injury. Chapman alleged that he encountered barriers at the Inn and was currently deterred from returning because of them.

LR Schoolhouse argued that it could not have caused Chapman’s injury because it allegedly did not own the Inn until April 8, 2022, after Chapman’s 2021 stay. The court rejected that argument at the motion-to-dismiss stage. It explained that a person with a disability does not have to make a futile attempt to access a place that may still have barriers. The court also found that uncertainty about whether the barriers remained could itself constitute an injury and that LR Schoolhouse had not shown that it corrected the alleged barriers.

The court stated that Chapman might not ultimately prevail if discovery showed that no ADA violations existed or that past violations had been corrected. At that stage, however, it held that Chapman had standing to pursue his ADA claim against LR Schoolhouse.

Sufficiency of the ADA allegations

To plead a Title III discrimination claim, Chapman had to allege that he was disabled under the ADA, that LR Schoolhouse was a private entity owning, leasing, or operating a place of public accommodation, and that he was denied access because of his disability. The court held that Chapman’s allegations about readily achievable barrier removal were sufficient.

LR Schoolhouse initially argued that Chapman needed to identify which version of the ADA Accessibility Guidelines applied to the Inn. In its reply, it argued that Chapman had to identify each barrier that was not compliant and specify which barriers could be removed at reasonable cost. The court rejected those arguments. It held that Chapman had described the barriers in detail and alleged that removing some or all of them was readily achievable. The court stated that a plaintiff need not provide a complete cost-efficiency proposal at the pleading stage.

California Unruh Act claim

LR Schoolhouse argued that Chapman could pursue a California Unruh Civil Rights Act claim only for barriers he personally experienced. The court rejected the argument at this stage. Chapman alleged that he was deterred from booking an October 2022 reservation for a stay between November 2022 and February 2023, when LR Schoolhouse admits it owned the Inn. The court held that the barriers Chapman experienced in 2021 supported a reasonable inference that they continued to exist when he considered the later reservation.

The court also held that LR Schoolhouse improperly asked it to draw inferences in the defendant’s favor. At the pleading stage, Chapman’s allegation of an intent to use the business’s services was sufficient; proof of a genuine intent to use those services would be required later, at summary judgment or trial.

Supplemental jurisdiction

The court decided to retain supplemental jurisdiction over Chapman’s state-law claims. Supplemental jurisdiction allows a federal court to hear related state-law claims that form part of the same case or controversy as a federal claim.

LR Schoolhouse asked the court to decline that jurisdiction based on a Ninth Circuit decision involving heightened pleading requirements for state accessibility claims brought by “high-frequency litigants.” The court declined. LR Schoolhouse had not argued that Chapman was a high-frequency litigant and had not shown exceptional circumstances supporting dismissal of the state claims. The court therefore did not decline supplemental jurisdiction.

Disposition and further proceedings

The court DENIED LR Schoolhouse’s motion to dismiss. The order did not resolve whether Chapman will ultimately prove his ADA or California claims.

The order also addressed the unserved defendant Kila Schoolhouse LLC. Chapman said he had been unable to serve Kila Schoolhouse and intended to seek permission to use alternative service. The court directed Chapman to file that motion by December 14, 2023, and set a February 1, 2024 case management conference concerning service on Kila Schoolhouse and whether the court’s General Order 56 process should begin. The order stated that it disposed of Docket No. 10.