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Lema v. Courtyard Marriott Merced

Citations: 873 F. Supp. 2d 1264; 2012 U.S. Dist. LEXIS 93002; 2012 WL 2617583Docket: Case No. 1:10-cv-01131-SMS

Court: District Court, E.D. California; July 5, 2012; Federal District Court

Narrative Opinion Summary

In this case, the Defendants filed a motion to dismiss the Plaintiff's first amended complaint on the grounds of lack of subject matter jurisdiction, lack of standing under the Americans With Disabilities Act (ADA), and failure to state a claim pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). The Court reviewed the motion and decided to strike it, emphasizing that the Plaintiff had adequately demonstrated standing by alleging discrimination in accessing public accommodations, consistent with ADA requirements. The Court noted that the ADA does not mandate detailed allegations of specific barriers. Furthermore, the Court found the Defendants' motion procedurally inappropriate as it was premature to treat it as a summary judgment motion, given that the Defendants had not yet answered the complaint. The Court expressed concerns over the Defendants' good faith, suggesting their tactics were intended to delay proceedings. Consequently, the Court struck any motions filed by the Defendants without prior permission and modified the procedural orders to establish firm deadlines for the Defendants to file their answer and any dispositive motions. The Defendants are prohibited from filing further motions without court approval until after these procedural requirements are satisfied.

Legal Issues Addressed

Court's Authority to Modify Procedural Orders

Application: Due to Defendants' attempts to delay, the Court modified the stipulated order to impose a strict timeline for filing answers and dispositive motions.

Reasoning: Due to Defendants' attempts to delay, the stipulated order is modified, requiring them to file their answer by July 13, 2012, with a dispositive motion deadline set for August 3, 2012.

Good Faith Requirement in Litigation

Application: The Court expressed concerns regarding Defendants' good faith, indicating their actions seemed aimed at delaying resolution.

Reasoning: The court also expresses concern over Defendants' good faith, indicating that their actions appear aimed at delaying resolution and imposing burdens on the court.

Procedural Handling of Motions under F.R.Civ.P. 12(b)(6)

Application: The Court struck the Defendants' motion to dismiss due to procedural inappropriateness, noting that it was premature to treat it as a summary judgment motion.

Reasoning: Since Defendants have not yet answered the first amended complaint, it would be premature to treat the motion as a summary judgment motion.

Standing under the Americans With Disabilities Act (ADA)

Application: The Court found that Plaintiff adequately demonstrated standing by alleging discrimination in accessing public accommodations, as defined under the ADA.

Reasoning: The Court confirmed that a plaintiff must show actual injury connected to the defendant's actions to establish standing and that courts must adopt a broad view of constitutional standing in ADA cases.

Sufficiency of Allegations in ADA Claims

Application: The Court clarified that the ADA does not require detailed allegations of specific barriers encountered by the Plaintiff.

Reasoning: Defendants now seek further specificity regarding which barriers relate to Plaintiff's disabilities and when these barriers were encountered. However, the Court clarified that the ADA does not require such detailed allegations.