Mortland v. Jairaj Dupont, LLC

CourtDistrict Court, N.D. Indiana
DecidedJanuary 30, 2025
Docket1:24-cv-00001
StatusUnknown

This text of Mortland v. Jairaj Dupont, LLC (Mortland v. Jairaj Dupont, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mortland v. Jairaj Dupont, LLC, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

DEREK MORTLAND,

Plaintiff,

v. Case No. 1:24-CV-1-CCB-SLC

JAIRAJ DUPONT, LLC,

Defendant.

ORDER Pending before the Court is Defendant Jairaj Dupont, LLC’s (“Jairaj Dupont”) Motion to Dismiss Plaintiff Derek Mortland’s Amended Complaisnt. (ECF 18). For the reasons set forth below, the Motion to Dismiss is denied. FACTUAL BACKGROUND In March 2023, Mortland, who is allegedly paralyzed and uses a wheelchair, stayed at a Hampton Inn hotel—an alleged public accommodation—in Fort Wayne, Indiana. (ECF 16 at ¶¶ 2, 5). The Hampton Inn is allegedly owned by Jairaj Dupont. (Id. at ¶ 2). Mortland alleges that he encountered several inaccessible elements and architectural barriers at the hotel, including in the room, restroom, breakfast area, and fitness room. (Id. at ¶¶ 16-17). Mortland alleges that he suffered personal physical injury to his shoulders, back, neck and spine when he had to maneuver around those barriers, and when he tried to use an inaccessible roll-in shower. (ECF 16 at ¶ 21). Mortland also alleges his intention to return to the hotel if it becomes accessible because he often travels to the Fort Wayne area for business and to visit friends, he has plans to visit a nearby local museum with his spouse in the summer, and the hotel’s rates are within his budget. (ECF 16 at ¶ 29).

Mortland thus sued Jairaj Dupont for denial of access to a public accommodation in violation of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. § 12101, et seq., and seeks injunctive relief. Jairaj Dupont argues that Mortland lacks Article III standing to bring this lawsuit, and moves to dismiss Mortland’s Amended Complaint under Fed. R. Civ. 12(b)(1) and 12(b)(6). STANDARD OF REVIEW

In Jairaj Dupont’s motion to dismiss, it makes fleeting assertions that Mortland has no “evidence” of having Article III standing. However, the Court construes Jairaj Dupont’s instant motion to dismiss under Fed. R. Civ. P. 12(b)(1) and (6) as asserting a facial challenge to Mortland’s amended complaint, not a factual challenge, because Jairaj Dupont contends that Mortland’s complaint lacks factual allegations to establish

standing.1 See Silha v. ACT, Inc., 807 F.3d 169, 173 (7th Cir. 2015). To 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.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 554 (2007)); accord McCauley v. City of Chicago, 671 F.3d 611, 616 (7th Cir. 2013) (a

complaint “must contain ‘allegations plausibly suggesting (not merely consistent with)’

1 A factual challenge, on the other hand, is one in which the Court evaluates whether “there is in fact no subject matter jurisdiction, even if the pleadings are formally sufficient,” and looks beyond the pleadings and views any evidence submitted to determine whether subject matter jurisdiction exists. Silha, 807 F.3d at 173. an entitlement to relief”). “[A] formulaic recitation of the elements of a cause of action,” and “naked assertions” without supporting facts are inadequate. Id. (quoting Twombly,

550 U.S. at 557). A complaint therefore fails to state a claim if it does not “describe the claim in sufficient detail to give the defendant fair notice of what the . . . claim is and the grounds upon which it rests [or] plausibly suggest that the plaintiff has a right to relief, raising that possibility above a speculative level.” E.E.O.C. v. Concentra Health Servs., Inc., 496 F.3d 773, 776 (7th Cir. 2007) (internal quotations omitted). When evaluating a facial challenge to subject matter jurisdiction under Rule

12(b)(1), the Court must “use Twombly-Iqbal’s ‘plausibility’ requirement, which is the same standard used to evaluate facial challenges to claims under Rule 12(b)(6).” Silha v. ACT, Inc., 807 F.3d 169, 173 (7th Cir. 2015). The Court must therefore “accept as true all well-pleaded factual allegations and draw all reasonable inferences in favor of the plaintiff” when evaluating whether a complaint adequately pleads standing. Id.

(“[S]tanding must be supported in the same way as any other matter on which the plaintiff bears the burden of proof[.]”). ANALYSIS Mortland, as the party invoking federal jurisdiction, bears the burden of demonstrating he satisfies the elements of Article III standing. See TransUnion LLC v.

Ramirez, 594 U.S. 413, 430–31 (2021). To establish Article III standing, a ”plaintiff must show (1) [he] has suffered an ‘injury in fact’ that is (a) concrete and particularized and (b) actual or imminent, not conjectural or hypothetical; (2) the injury is fairly traceable to the challenged action of the defendant; and (3) it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.” Friends of the Earth, Inc. v. Laidlaw Envtl. Servs. (TOC), Inc., 528 U.S. 167, 180–181 (2000). In addition,

where, as here, a plaintiff seeks prospective injunctive relief, he must also allege a “real and immediate”—not a “conjectural or hypothetical”—threat of a future violation of his rights. See City of Los Angeles v. Lyons, 461 U.S. 95, 102 (1983) (citation and internal quotation marks omitted); Scherr v. Marriott Inter'l, Inc., 703 F.3d 1069, 1074 (7th Cir. 2013). First, Jairaj Dupont argues that Mortland fails to sufficiently plead a concrete and

particularized injury fairly traceable to Jairaj Dupont’s alleged conduct. (ECF 19 at 6-7). Mortland alleges that he suffered “personal physical injury to his shoulders, back, neck, and spine” from moving around the barriers at the Hampton Inn and when he attempted to use the Hampton Inn’s amenities. (ECF 16 at ¶ 21). Tangible harms, such as physical harms, “readily qualify as concrete injuries under Article III.” TransUnion

LLC v. Ramirez, 594 U.S. 413, 425 (2021). Accepting Mortland’s allegations as true, Mortland plausibly alleges that he suffered a concrete and particularized injury fairly traceable to Jairaj Dupont. While Jairaj Dupont expresses its doubts as to Mortland’s physical injuries, it is not for the Court to evaluate whether Mortland actually suffered any injuries so as to confer standing at the motion-to-dismiss stage.

Lastly, Jairaj Dupont argues that Mortland lacks standing to pursue prospective injunctive relief because his alleged future visits to the Hampton Inn are insufficient to demonstrate real and immediate threat of future violations of his rights. (ECF 19 at 10). Mortland alleges in his amended complaint that in the future he would visit the Hampton Inn if it became accessible because he frequents Fort Wayne for work and to visit friends, and the Hampton Inn is near a museum Mortland intends to visit with his

spouse.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

City of Los Angeles v. Lyons
461 U.S. 95 (Supreme Court, 1983)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Brewster McCauley v. City of Chicag
671 F.3d 611 (Seventh Circuit, 2011)
Scherr v. Marriott International, Inc.
703 F.3d 1069 (Seventh Circuit, 2013)
Cathleen Silha v. ACT, Inc.
807 F.3d 169 (Seventh Circuit, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Mortland v. Jairaj Dupont, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mortland-v-jairaj-dupont-llc-innd-2025.