Whitaker v. Tesla Motors, Inc., No. 19-56497 (9th Cir. 2021)
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The Ninth Circuit affirmed the district court's dismissal of plaintiff's action under Title III of the Americans with Disabilities Act (ADA) based on failure to state a claim. Plaintiff, a quadriplegic who uses a wheelchair for mobility, alleges that he encountered inaccessible service counters that denied him full and equal access to a Tesla dealership and "created difficulty and discomfort." Plaintiff also alleges that Tesla's continued failure to provide accessible service counters deters him from returning to the dealership.
The panel held that plaintiff's complaint did not allege facts sufficient to support his claim under the standards articulated by Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007). The court concluded that the district court correctly concluded that plaintiff's complaint did not allege facts sufficient to support his ADA claim because the complaint primarily recited legal conclusions. Furthermore, Tesla was not put on notice of how its service counters prevented plaintiff from full and equal access to a Tesla dealership. Finally, the panel sua sponte addressed the issue of standing and concluded that plaintiff's allegations were sufficient to establish an injury-in-fact.
Court Description: Americans with Disabilities Act. The panel affirmed the district court’s dismissal, for failure to state a claim, of an action under Title III of the Americans with Disabilities Act. The panel held that plaintiff’s allegations were not sufficient to satisfy the standards articulated by Ashcroft v. Iqbal and Bell Atlantic Corp. v. Twombly, which, taken together, require well-pleaded facts, not legal conclusions, that plausibly give rise to an entitlement to relief. The panel concluded that plaintiff’s complaint did not allege facts sufficient to support his ADA claim against Tesla, Inc., because the complaint primarily recited legal conclusions and did not put Tesla on notice of how its service counters prevented plaintiff from full and equal access to a Tesla dealership. * The Honorable Barrington D. Parker, Jr., Senior United States Circuit Judge for the U.S. Court of Appeals for the Second Circuit, sitting by designation. WHITAKER V. TESLA MOTORS 3 Addressing standing sua sponte, the panel held that plaintiff’s allegations that he uses a wheelchair for mobility, that he visited the defendant’s premises, that he personally encountered a barrier related to his disability, and that the barrier deters him from returning were sufficient to establish injury-in-fact for purposes of standing.
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