Hillesheim v. Holiday Stationstores, Inc., No. 17-3143 (8th Cir. 2018)Annotate this Case
Plaintiff, who is paralyzed from the waist down and uses a wheelchair for mobility, filed suit against Holiday, alleging that the company discriminated against him in violation of the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA) by failing to have an accessible parking lot at one of its stores. The district court granted Holiday's motion for summary judgment.
The Eighth Circuit vacated the district court's judgment with instructions to remand plaintiff's access-aisle and vertical-signage claims to state court. In regard to these two claims, plaintiff suffered no injury and thus could not establish Article III standing. The court also remanded for the district court to consider whether to exercise supplemental jurisdiction over the remaining garbage-can claim. In this case, plaintiff established an injury in fact by offering specific evidence that the allegedly dangerous circumstances caused him not to enter the store. The district court erred in treating a photograph that plaintiff submitted along with his declaration as definitive proof that he had plenty of room to maneuver around the garbage can.