Dalton v. NPC International, Inc., No. 18-2123 (8th Cir. 2019)
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Plaintiff filed suit against NPC, seeking declaratory and injunctive relief for alleged violations of the Americans with Disabilities Act (ADA), and corresponding ADA Accessibility Guidelines (ADAAG). Plaintiff, who has cerebral palsy and requires a wheelchair for mobility, alleged that NPC's restaurant failed to make its place of public accommodation fully accessible to persons with disabilities.
The Eighth Circuit held that plaintiff's parking lot violations claim was moot, because NPC corrected the access aisles the month after plaintiff filed his complaint. The court also affirmed the dismissing of the three other claims, because plaintiff lacked standing to challenge the remaining architectural barriers. In this case, he never entered the building at issue and never suffered any injury. The court held that the district court erroneously concluded that plaintiff had standing to challenge all of the alleged barriers and thus dismissed the case with prejudice. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings.
Court Description: Benton, Author, with Wollman and Grasz, Circuit Judges] Civil case - Americans with Disabilities Act. Plaintiff's complaints about the parking lot at defendant's Fergus Falls Pizza Hut were properly dismissed as moot; plaintiff lacks standing to challenge the remaining architectural barriers alleged in his complaint as he never entered the building and never suffered any injury; because plaintiff lacked standing, the district court erred in dismissing the claims with prejudice; case remanded for further proceedings.
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