Aaron Private Clinic Management LLC v. Commissioner of the Georgia Department of Community Health
912 F.3d 1330
11th Cir.2019Background
- Aaron Private Clinic Management (Georgia LLC) sued state officials challenging two Georgia statutes: a 2016 temporary moratorium on new narcotic-treatment program licenses and a 2017 statute that extended and replaced the moratorium with new licensing procedures and periodic application windows.
- Aaron alleged it intended to establish an opioid/methadone treatment program, asserted harms including lost business opportunities, extra costs, and stigma, and sued under Title II of the ADA and Section 504 of the Rehabilitation Act seeking damages, declaratory relief, and an injunction.
- The complaint pleaded few operative facts about Aaron’s readiness to open a clinic (no lease, permits, site, completed funding, or submitted license application) and relied largely on generalized allegations about statewide need for methadone treatment.
- The district court dismissed for lack of standing; the Eleventh Circuit reviewed de novo and considered mootness sua sponte for the moratorium claims.
- The court held the injunctive/declaratory claims about the expired moratorium provisions were moot and affirmed dismissal for lack of Article III standing because Aaron failed to allege a concrete, imminent injury and thus also could not assert third-party standing on behalf of prospective patients.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of injunction/declaration re: temporary moratorium | Moratorium injured Aaron by blocking clinic licensing | Moratorium expired; claims moot | Moot: moratorium provisions expired; no exception applies |
| Article III standing — injury-in-fact (lost profits/blocked clinic) | Aaron would have opened a clinic but-for statutes; lost profits and business opportunity | Aaron lacks concrete, imminent plans; injury speculative | No standing: mere ‘some day’ intent insufficient |
| Article III standing — incurred costs/fees from delays | Aaron incurred concrete costs, fees, and cost of capital from planning delays | Allegations too vague; cannot trace to statutes without showing readiness | No standing: costs allegations too conclusory and unconnected |
| Third-party standing to assert clients’ ADA/Rehab Act rights | Aaron may sue on behalf of prospective disabled clients harmed by restrictions | Aaron lacks its own injury and thus cannot assert third-party claims | No third-party standing: Aaron lacks injury in fact; therefore fails third-party test |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (establishes injury-in-fact, causation, redressability standing framework)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (plaintiff must allege concrete facts to demonstrate Article III standing at pleading stage)
- Village of Arlington Heights v. Metropolitan Housing Dev. Corp., 429 U.S. 252 (plaintiff challenging action blocking a development must show substantial probability project would have proceeded)
- Warth v. Seldin, 422 U.S. 490 (plaintiff must plead specific, concrete facts showing personal harm and benefit from relief)
- Young Apartments v. Town of Jupiter, 529 F.3d 1027 (third-party standing requires plaintiff injury, close relation, and hindrance to third party)
- A Helping Hand, LLC v. Baltimore Cty., 515 F.3d 356 (illustrative methadone-clinic standing case where plaintiff had concrete steps like lease, permits, and certifications)
- Hunt v. Aimco Properties, 814 F.3d 1213 (mootness and requirement to consider mootness sua sponte on appeal)