Hillesheim v. Holiday Stationstores, Inc., No. 17-3151 (8th Cir. 2018)
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Plaintiff filed suit against Holiday Stationstores, alleging claims for discrimination under the Americans with Disabilities Act and the Minnesota Human Rights Act (MHRA) based on the company's failure to provide a compliant handicap-accessible parking space at one of its stores. The district court granted Holiday's motion for summary judgment and dismissed plaintiff's claims.
The Eighth Circuit held that the district court did not abuse its discretion when it denied plaintiff's motion to strike the affidavit of Holiday's Vice President of Engineering. The court vacated the district court's judgment dismissing the ADA claim and held that, although the ADA claim was moot after Holiday permanently flattened the access aisle, it was wrong to dismiss the claim because the proper procedure was to remand the claim to state court. Furthermore, the portion of the judgment dismissing plaintiff's claim for injunctive relief under the Minnesota Human Rights Act must also be vacated and remanded to state court. Finally, the court held that plaintiff's claim for damages under the MHRA was not moot and the district court should, on remand, determine whether it wished to exercise supplemental jurisdiction over this claim.
Court Description: Stras, Author, with Wollman and Arnold, Circuit Judges] Civil case - Americans with Disabilities Act. Plaintiff brought this ADA and Minnesota Human Rights Action in state court alleging defendant had denied him full and equal access to a place of public accommodation by failing to provide a compliant handicap-accessible parking space at one of its stores; the matter was removed to federal court and defendant moved for summary judgment based on remediation of the violation; defendant's Rule 26 violation concerning disclosure of the renovation was harmless; the district court properly found the renovation made the ADA claim moot; however, the district court erred in dismissing the claim, becausethe proper procedure to be followed when a federal court lacks subject-matter jurisdiction over a a removed claim is to remand the claim to state court; therefore, the district court's judgment dismissing the ADA claim is vacated with directions to remand the claim to state court; similarly, the portion of the judgment dismissing plaintiff's claim for injunctive relief under the Minnesota Human Rights Act must also be vacated and remanded to state; plaintiff's claim for damages under the MHRA is not moot and the district court, on remand, should determine whether it wishes to exercise supplemental jurisdiction over this one remaining claim.
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