Hardy v. 1901 Sophie Wright, LLC

CourtDistrict Court, E.D. Louisiana
DecidedMarch 25, 2025
Docket2:23-cv-07043
StatusUnknown

This text of Hardy v. 1901 Sophie Wright, LLC (Hardy v. 1901 Sophie Wright, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hardy v. 1901 Sophie Wright, LLC, (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA THADDEUS HARDY CIVIL ACTION VERSUS NO. 23-7043 1901 SOPHIE WRIGHT, LLC, ET AL. SECTION “O” ORDER AND REASONS Before the Court in this disability-discrimination case is the Federal Rule of Civil Procedure 12(b)(6) motion1 of Defendant 1901 Sophie Wright, LLC, d/b/a Café

Roma, to dismiss Plaintiff Thaddeus Hardy’s claims for violations of Title III of the Americans with Disabilities Act of 1990, 42 U.S.C. §§ 12181–12189 (“ADA”), and the Louisiana Commission on Human Rights, LA. STAT. ANN. §§ 51:2231–2265 (“LCHR”). Hardy is a paraplegic who uses a wheelchair to move about. After he was unable to enter Italian restaurant Café Roma because of a step-up into the restaurant, Hardy sued the restaurant owner (1901 Sophie Wright, LLC) and the property owner (1800 OCH, LLC) for violating the ADA and the LCHR. The

restaurant owner now moves to dismiss, contending (1) a lease not specifically referred to in the complaint proves it lacked control over the step-up into the restaurant; and (2) photographs not referred to in the complaint prove the restaurant is ADA-compliant. But these arguments rest on material the Court may not properly consider at this stage; they are suited for a summary judgment motion—not for a Rule 12(b)(6) motion. Accordingly, for these reasons and those that follow, the motion

is DENIED.

1 ECF No. 13. I. BACKGROUND This disability-discrimination action arises from Thaddeus Hardy’s claim that he could not enter Café Roma—an Italian restaurant owned and operated by 1901

Sophie Wright and located on property owned by 1800 OCH—by wheelchair because there is a step-up into the restaurant and there is no ramp.2 Because this case comes to the Court on 1901 Sophie Wright’s Rule 12(b)(6) motion to dismiss, the facts that follow are drawn from the well-pleaded allegations of Hardy’s complaint. See generally Club Retro, L.L.C. v. Hilton, 568 F.3d 181, 190 (5th Cir. 2009). Hardy is a paraplegic who uses a wheelchair to move about.3 1901 Sophie Wright owns and operates Café Roma;4 1800 OCH owns the property.5 Hardy alleges

that he visited Café Roma but could not enter because there is a step-up into the restaurant and there is no ramp.6 Hardy alleges that he lives less than a mile from Café Roma and that he plans to return there to dine.7 But Hardy alleges that he “fears that he will encounter the same barriers to access[ing]” the restaurant.8 And Hardy alleges that those “barriers” are “the responsibility of” both “Defendants.”9 Hardy sued 1901 Sophie Wright and 1800 OCH in this Court for violating the

ADA and the LCHR.10 His complaint does not mention any lease between 1901

2 See generally ECF No. 1. 3 Id. at ¶ 7. 4 Id. at ¶ 9. 5 Id. at ¶ 8. 6 Id. at ¶ 18. 7 Id. at ¶¶ 20–21. 8 Id. at ¶ 21. 9 Id. at ¶ 22 (capitalization modified). 10 Id. at ¶¶ 14–27 (ADA); id. at ¶¶ 28–36 (LCHR). Sophie Wright and 1800 OCH and includes no pictures of the property.11 Hardy ultimately asks the Court for a declaration that the property “is in violation of the ADA and the LCHR”; an order directing 1901 Sophie Wright and 1800 OCH “to alter

the [p]roperty to make it accessible to and useable by individuals with mobility disabilities”; damages under the LCHR “for the discriminatory conduct” of 1901 Sophie Wright and 1800 OCH; and attorney’s fees, costs, and other expenses.12 Now, 1901 Sophie Wright moves to dismiss Hardy’s complaint under Rule 12(b)(6) for failure to state a claim.13 Hardy opposes.14 II. LEGAL STANDARD Rule 8(a)(2) requires “a short and plain statement of the claim showing that

the pleader is entitled to relief.” FED. R. CIV. P. 8(a)(2). A complaint that does not meet Rule 8(a)(2)’s pleading standard should be dismissed for failing to state a claim upon which relief can be granted. FED. R. CIV. P. 12(b)(6). “[T]he pleading standard Rule 8 announces does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell. Atl. Corp. v. Twombly, 550 U.S. 544,

555 (2007)). “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitations of the elements of a cause of action will not do.’” Id. (quoting Twombly, 550 U.S. at

11 Id. at ¶¶ 1–36. 12 Id. at prayer ¶ A–D. 13 ECF No. 13. 14 ECF No. 14. Originally, 1800 OCH also opposed 1901 Sophie Wright’s motion. ECF No. 15. But the Court has since granted 1800 OCH’s motion to withdraw its opposition. ECF No. 26. 555). “Nor does a complaint suffice if it tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement.’” Id. (quoting Twombly, 550 U.S. at 557). Ultimately, “[t]o survive a motion to dismiss” under Rule 12(b)(6), “a complaint

must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Id. (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). “Although ‘[courts] accept all well-pled facts as true, construing all reasonable inferences in the complaint in the light most favorable to the plaintiff, conclusory allegations, unwarranted factual inferences, or legal

conclusions are not accepted as true.’” Hodge v. Engleman, 90 F.4th 840, 843 (5th Cir. 2024) (quoting Allen v. Hays, 65 F.4th 736, 743 (5th Cir. 2023)). III. ANALYSIS 1901 Sophie Wright contends that Hardy fails to state any claims against it for two reasons. But both rely on material outside the pleadings that the Court may not consider at the Rule 12(b)(6) stage. So neither argument persuades in this posture.

First, 1901 Sophie Wright submits that Hardy fails to state any claims against it because it had no control over the step-up outside the restaurant that Hardy says precluded his entry.15 For support, 1901 Sophie Wright points to the language of a lease between it and 1800 OCH that is not specifically referenced in the complaint.16

15 ECF No. 13-1 at 2–4. 16 Id. at 3; see also ECF No. 13-2 (lease). The Court may not dismiss Hardy’s claims under Rule 12(b)(6) based on the lease. “[A] Rule 12(b)(6) motion typically cannot rely on evidence outside the complaint.” C&C Inv. Props., L.L.C. v. Trustmark Nat’l Bank, 838 F.3d 655, 660 (5th

Cir. 2016). But that general rule is subject to two exceptions: The Court “may rely on evidence outside the complaint, without converting a Rule 12(b)(6) motion into a motion for summary judgment, if that evidence is either (a) a document attached to the Rule 12(b)(6) motion, referred to in the complaint, and central to the plaintiff’s claim; or (b) a matter subject to judicial notice under Federal Rule of Evidence 201.” George v. SI Grp., Inc., 36 F.4th 611, 619 (5th Cir. 2022) (citing Walker v. Beaumont Indep. Sch. Dist., 938 F.3d 724, 735 (5th Cir. 2019)).

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Club Retro, L.L.C. v. Hilton
568 F.3d 181 (Fifth Circuit, 2009)
Calvin Walker v. Beaumont Indep School Dist
938 F.3d 724 (Fifth Circuit, 2019)
George v. SI Grp
36 F.4th 611 (Fifth Circuit, 2022)
Hodge v. Engleman
90 F.4th 840 (Fifth Circuit, 2024)

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Hardy v. 1901 Sophie Wright, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hardy-v-1901-sophie-wright-llc-laed-2025.