Suarez-Torres v. Panaderia y Reposteria Espana, Inc., No. 18-1618 (1st Cir. 2021)
Annotate this Case
In this appeal arising from a lawsuit brought under the Americans with Disabilities Act (ADA) and the Puerto Rico Civil Rights Act the First Circuit affirmed the decision of the district court denying Plaintiffs' post-judgment motion for attorney's fees and motion to reopen, holding that the district court did not abuse its discretion.
In their complaint, Plaintiffs alleged that they encountered barriers to their equal access and full enjoyment of Defendants' facilities, services, goods, and amenities. Plaintiffs later moved for final judgment on their ADA claims, claiming that they obtained the requested relief under federal law because Defendants had agreed to make challenges or adjustments to the design of the locale. The district court dismissed the claims without prejudice, stating that Plaintiffs may file a motion to reopen if Defendants failed to comply with the agreed-upon deadlines. Plaintiffs then moved for attorney's fees, arguing that they were the prevailing parties under the ADA's fee-shifting provision, 42 U.S.C. 12205. The district court denied the motion. The First Circuit affirmed, holding (1) Plaintiffs failed to demonstrate the requisite judicial imprimatur on the outcome to make them prevailing parties; and (2) the district court did not abuse its discretion in declining to reopen the case based on Appellants' allegations.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.