Karla Brintley v. Belle River Community Credit Union

Citation: Not availableDocket: 18-2328

Court: Court of Appeals for the Sixth Circuit; August 27, 2019; Federal Appellate Court

Original Court Document: View Document

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Karla Brintley, a blind resident of Michigan, filed a lawsuit against Aeroquip Credit Union and Belle River Community Credit Union, alleging violations of the Americans with Disabilities Act (ADA) due to their websites' inaccessibility. Despite her claims, the court found that Brintley did not meet the requirements for Article III standing, specifically lacking an "injury in fact" because she was ineligible to join either credit union and did not express any interest in becoming eligible. The credit unions had moved to dismiss the case on these grounds, but the district court initially rejected their motions. The appellate court ultimately reversed the district court's decision, emphasizing that Brintley failed to demonstrate a constitutional injury necessary to pursue her claim.

Brintley must demonstrate an invasion of a "legally protected interest" that is "concrete and particularized" as well as "actual or imminent." Her alleged injury must be "real" and affect her in a "personal and individual way." However, the credit unions did not injure her because state law prohibits her from accessing their financial services, as Michigan law restricts membership to those within a specific "field of membership" based on shared community interests. Brintley does not qualify for these fields, and her complaint does not indicate any intention to change her status.

Two circuit courts have dismissed similar claims, reinforcing the notion that a plaintiff barred by law from using services cannot demonstrate a concrete injury. Brintley's assertion of wanting to use the credit unions' services does not establish an actual or imminent injury since she has not made efforts to become eligible. Without concrete plans to change her situation, her intent fails to meet the injury-in-fact requirement.

Moreover, Brintley's argument that the Americans with Disabilities Act does not necessitate a client or customer requirement lacks support, as the Supreme Court has not conclusively ruled on this issue. Even if she were correct on that point, it would not affect her Article III standing, which requires proof of injury in fact. Other courts have allowed non-client claims only when the plaintiff independently establishes injury, underscoring the necessity for Brintley to demonstrate an actual injury to proceed with her claim.

Brintley asserts a right to fully access the credit unions' websites to evaluate potential membership, akin to sighted individuals. However, since she has not expressed intent to join either credit union, she cannot establish a legal standing for her claim under the Americans with Disabilities Act (ADA). The precedent set in Griffin emphasizes the need for a specific connection between the plaintiff and the defendant for claims of injury. Brintley's argument for freestanding informational harm is dismissed, as it was not raised earlier and lacks merit; a procedural violation alone does not justify federal court jurisdiction. To succeed, Brintley must demonstrate that the information on the websites has relevance to her, which her amended complaint fails to do. Her claims about the usefulness of the websites' services for non-members or potential sharing with acquaintances remain speculative and unsubstantiated. Additionally, her assertion of dignitary harm does not satisfy the requirements for standing under Article III, as she has not shown that she is personally affected by the alleged discrimination. Assertions of abstract harm are insufficient to confer legal standing, as highlighted by case law.

Standing to sue in federal court requires a direct and personal injury, which Brintley has not established. If standing were broadly applied, it could allow any citizen to challenge distant government actions or unrelated projects, undermining judicial efficiency. Brintley's browsing of websites, without a more substantial connection or injury, does not satisfy Article III requirements. Michigan law prohibits her from accessing services from the credit unions in question, further weakening her claim of injury. While Brintley argues that her experience with the websites constitutes a personal encounter with discrimination, such an interpretation could lead to a flood of lawsuits from many others who similarly browse inaccessible sites, which is not permissible under current law. Although civil rights cases may allow broader standing, this does not exempt Brintley from constitutional requirements. Recent Supreme Court decisions have tightened the criteria for what constitutes an injury in fact, reinforcing the need for a concrete personal stake in the litigation. The court ultimately reverses the decision, with a concurrence noting Brintley’s failure to demonstrate that the websites offered services she could utilize, rather than a blanket inability for non-members to challenge website accessibility.