Kohler v. Bed Bath & Beyond of Cal., LLC, No. 12-56520 (9th Cir. 2015)
Annotate this CasePlaintiff, who was disabled and used a wheelchair, brought suit against Bed Bath & Beyond of California (BB&B), claiming violations of Title II of the Americans with Disabilities Act (ADA) and related state law provisions for ten purported access barriers. The district court granted summary judgment for BB&B and concluded that several of Plaintiff’s claims warranted an award of attorneys’ fees to BB&B. The Ninth Circuit affirmed in part and reversed in part, holding (1) the district court correctly granted summary judgment in favor of BB&B, as (i) Plaintiff’s claim regarding clearance next to a restroom door in a store was without merit, as the ADA Accessibility Guidelines do not require any length of wall space on the side of the doorframe opposite the hinges; and (ii) BB&B, as a tenant, was not liable for ADA violations occurring in the parking lot outside of its store where that area was controlled by the landlord and not leased by Defendant; but (2) the district court erred in concluding that eight of Plaintiff’s ten claims were frivolous, and therefore, BB&B was not entitled to attorneys’ fees for any of Plaintiff’s claims.
Court Description: Americans with Disabilities Act. The panel affirmed the district court’s summary judgment and reversed its award of attorneys’ fees in favor of the defendant in an action under Title III of the Americans with Disabilities Act. Affirming the grant of summary judgment on a claim regarding clearance next to a restroom door in a store, the panel followed the holding of Kohler v. Bed Bath & Beyond of Cal., LLC, ___ F.3d ___, No. 12-56727, slip op. at 11–12 (9th Cir. Feb. 19, 2015), that the ADA Accessibility Guidelines do not require any length of wall space on the side of the doorframe opposite the hinges. KOHLER V. BED BATH & BEYOND 3 The panel also affirmed the district court’s ruling that the defendant, as a tenant, was not liable for ADA violations occurring in the parking lot outside of its store where that area of the property was controlled by the landlord and was not leased by the defendant. Reversing the district court’s award of attorneys’ fees to the defendant as a prevailing party, the panel held that the district court erred in concluding that eight of the plaintiff’s ten claims were frivolous.
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.