Benford v. Legend Auto Works Inc.
2:25-cv-05795
| C.D. Cal. | Jun 30, 2025Background
- Plaintiff Sam Benford filed a lawsuit against Legend Auto Works Inc. alleging violations under the Americans with Disabilities Act (ADA) and state law claims.
- The Court emphasizes its preference for swift resolution of civil disputes and reminds parties about the possibility of mootness where alleged ADA barriers are removed pre-trial.
- The Court instructed both parties to file a joint status report, detailing actions taken by the defendant regarding alleged ADA barriers and the plaintiff’s position.
- Plaintiff also invoked the Court’s supplemental jurisdiction to pursue state law claims, including under California’s Unruh Act.
- The Court ordered Plaintiff to show cause why supplemental jurisdiction should be retained over state law claims and to provide information regarding statutory damages and possible designation as a "high-frequency litigant."
- Failure to respond as directed may result in dismissal of the entire action or of the state law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of ADA Claims if Barriers Remedied | ADA claim should proceed despite remedial steps | ADA claims should be dismissed if barriers are remedied and unlikely to recur | Court clarifies ADA claim may be dismissed if barriers remedied and no reasonable expectation of recurrence |
| Availability of Nominal Damages under ADA Title III | Plaintiff may seek damages for ADA violations | Nominal damages not available under ADA Title III | Court finds nominal damages unavailable under Title III |
| Supplemental Jurisdiction over State Law Claims | Federal court should retain jurisdiction for state claims | If ADA claim dismissed as moot, state claims should be dismissed or remanded | Court may decline jurisdiction over state claims if ADA claim is moot |
| Entitlement to Attorney’s Fees if ADA Claim Mooted | Plaintiff may seek fees for preliminary relief | No fees if ADA claim is rendered moot pre-trial | Court affirms no attorney’s fees if ADA claim is moot |
Key Cases Cited
- Oliver v. Ralphs Grocery Co., 654 F.3d 903 (9th Cir. 2011) (defendant’s voluntary removal of barriers may moot ADA claim)
- Am. Cargo Transp., Inc. v. United States, 625 F.3d 1176 (9th Cir. 2010) (mootness doctrine applies to federal statutory claims)
- Buckhannon Bd. & Care Home, Inc. v. W. Va. Dept. of Health & Human Resources, 532 U.S. 598 (2001) (no attorney’s fees where plaintiff is not prevailing party because claim is moot)
- City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (factors for exercising supplemental jurisdiction)
- Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (judicial economy, convenience, fairness, and comity in supplemental jurisdiction analysis)