Brian Whitaker v. SV Investment Group Partners, LLC

CourtDistrict Court, C.D. California
DecidedFebruary 26, 2020
Docket2:19-cv-07013
StatusUnknown

This text of Brian Whitaker v. SV Investment Group Partners, LLC (Brian Whitaker v. SV Investment Group Partners, LLC) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brian Whitaker v. SV Investment Group Partners, LLC, (C.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 Brian Whitaker, Case: 2:19-cv-07013-SVW-JEM 12 Plaintiff, Judgment Following Bench 13 v. Trial 14 Farhad Yaghoubi; Elham Yaghoubi; and Does 1-10, 15 Defendants. Hon. Judge Stephen V. Wilson 16 17 18 19 I. INTRODUCTION 20 Plaintiff Brian Whitaker, who is quadriplegic, brought this action because 21 Defendants failed to provide an accessible sales counter and accessible paths of 22 travel at Marco Ferno (“Store”) at or about 746 S. Los Angeles Street, Los 23 Angeles, California on the date of Plaintiff’s visit on August 3, 2019. Plaintiff 24 25 sought a ruling that his rights were violated under the Americans with Disabilities 26 Act and Unruh Civil Rights Act, a single statutory penalty of $4,000, and an order 27 requiring Defendants to make the sales counter and paths of travel at the Store 28 accessible. 1 Defendants failed to appear at the bench trial on January 23, 2020. Upon 2 review of the evidence submitted by the Plaintiff, the Court grants JUDGMENT in 3 favor of Plaintiff Brian Whitaker and against Defendants Farhad Yaghoubi and 4 Elham Yaghoubi as to both claims: A $4,000 statutory penalty under the Unruh 5 Civil Rights Act, and declaratory relief under the ADA, enjoining defendants to 6 make the sales counter and paths of travel at the Store accessible per the Americans 7 with Disabilities Act of 1990. 8 9 II. THE LACK OF ACCESSIBLE FACILITIES Under 10 Title III of the Americans With Disabilities Act of 1990 (“ADA”), the general 11 rule is that: “No individual shall be discriminated against on the basis of a 12 disability in the full and equal enjoyment of the goods, services, facilities, 13 privileges, advantages, or accommodations of any place of public accommodation 14 by any person who owns, leases (or leases to), or operates a place of public 15 accommodation.” 42 U.S.C. § 12182(a). The term “discrimination” can be 16 misleading. The ADA applies not just to intentional discrimination but to 17 thoughtlessness and indifference: 18 Its passage was premised on Congress's finding that discrimination 19 against the disabled is most often the product, not of invidious animus, but rather of thoughtlessness and indifference, of benign 20 neglect, and of apathetic attitudes rather than affirmative animus. 21 The concept of “discrimination” under the ADA does not extend only to obviously exclusionary conduct—such as a sign stating that 22 persons with disabilities are unwelcome or an obstacle course 23 leading to a store's entrance. Rather, the ADA proscribes more subtle forms of discrimination—such as difficult-to-navigate restrooms and 24 hard-to-open doors—that interfere with disabled individuals' “full 25 and equal enjoyment” of places of public accommodation. Chapman v. Pier 1 Imports (U.S.) Inc., 631 F.3d 939, 944-45 (9th Cir. 2011) 26 (internal quotes and citations removed for readability). 27 28 1 To succeed on his Title III, ADA claim, “a plaintiff must show that: (1) he is 2 disabled within the meaning of the ADA; (2) the defendant is a private entity that 3 owns, leases, or operates a place of public accommodation; and (3) the plaintiff 4 was denied public accommodations by the defendant because of his disability.” 5 Arizona ex rel. Goddard v. Harkins Amusement Enterprises, Inc., 603 F.3d 666, 6 670 (9th Cir. 2010). “The third element—whether plaintiffs were denied public 7 accommodations on the basis of disability—is met if there was a violation of 8 applicable accessibility standards.” Moeller v. Taco Bell Corp., 816 F.Supp.2d 9 831, 847 (N.D. Cal. 2011) citing, Chapman, 631 F.3d at 945. This is because 10 discrimination is defined both as either a failure to ensure that alterations are 11 “readily accessible to and useable by persons with disabilities” and, where there 12 are no alterations, “a failure to remove architectural barriers… in existing 13 facilities… where such removal is readily achievable.” 42 U.S.C. §§ 12183(a)(2); 14 12182(b)(2)(A)(iv). Thus, the following is a simplified statement of the elements 15 necessary for the plaintiff to prove discrimination under this section: 16 1. Plaintiff must be disabled. 42 U.S.C. § 12182(a); 17 2. The defendants’ facility must be a place of "public accommodation" and, 18 therefore, governed by Title III of the ADA Id.; 19 3. The defendants must be responsible parties, i.e., owners, operators, lessors 20 or lessees. Id.; 21 4. The defendants’ facility must have either undergone an alteration that did 22 not comply with the access standards or contain an easily removed barrier 23 that the defendants failed to remove. 42 U.S.C. §§ 12183(a)(2); 24 12182(b)(2)(A)(iv); 25 5. Plaintiff must have actually encountered this non-removed and unlawful 26 barrier. 42 U.S.C. § 12188(a). 27 As discussed below, Mr. Whitaker’s civil rights were violated because the 28 Defendants failed to provide accessible facilities at the Store. 1 A. Plaintiff is Disabled 2 Mr. Whitaker is a man with severe mobility impairments who has limited 3 ability to walk and uses a wheelchair for mobility. Thus, there can be little doubt 4 that he fits the qualification under the Americans with Disabilities Act as a person 5 with a disability. 42 U.S.C. § 12102(2)(A) (defining a physical impairment 6 substantially affecting a major life activity as qualifying as a disability). Given 7 Mr. Whitaker’s limited ability to walk, this is not a genuine issue. 8 9 B. Defendants Own and Operate a Place of Public 10 Accommodation 11 The Store is an establishment selling men’s clothing. Clothing stores and 12 other sales establishments are expressly identified under the ADA as places of 13 public accommodation. 42 U.S.C. § 12181(7)(E). Defendants owned the Marco 14 Ferno store and the property it is located on during Mr. Whitaker’s visit and do so 15 currently. Defendants, therefore, have an obligation to comply with the anti- 16 discrimination provisions of Title III of the Americans with Disabilities Act. 17 C. The Store Had Barriers That Were Readily Removed 18 The ADA defines “discrimination” as a failure to remove architectural 19 barriers where it is readily achievable to do so. 42 U.S.C. § 12182(b)(2)(A)(iv). 20 The term “barrier” is not defined in the Act itself but is defined in the Technical 21 Assistance Manual: 22 23 III-4.4100: What is an architectural barrier? Architectural barriers 24 are physical elements of a facility that impede access by people with disabilities. These barriers include more than obvious impediments 25 such as steps and curbs that prevent access by people who use 26 wheelchairs. 27 Department of Justice, Technical Assistance Manual on the American with 28 Disabilities Act (BNA) §§ III-4.4100 (1991). 1 Case law is more specific. “To determine if Plaintiff describes an 2 ‘architectural barrier’ the Court must turn to the ADA Accessibility Guidelines for 3 Buildings and Facilities (“ADAAG”).

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Bluebook (online)
Brian Whitaker v. SV Investment Group Partners, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brian-whitaker-v-sv-investment-group-partners-llc-cacd-2020.