Chapman v. Pier 1 Imports (U.S.) Inc.
631 F.3d 939
| 9th Cir. | 2011Background
- Chapman, a wheelchair user, sued Pier 1 Imports store in Vacaville alleging ADA barriers denied him full and equal enjoyment.
- Chapman sought injunctive relief to remove barriers he encountered and those he did not encounter but which might affect future visits, plus California damages.
- Discovery produced Card Report listing 30 alleged barriers; district court granted summary judgment to Pier One on many barriers.
- An en banc panel clarified standing rules, allowing injunctive relief for encountered barriers and related unencountered barriers if injury-in-fact and intent to return or deterrence are shown.
- On remand, the court vacated summary judgment and remanded to dismiss Chapman's ADA claim for lack of jurisdiction due to insufficient standing allegations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to seek injunctive relief for unencountered barriers | Chapman has injury-in-fact and intends to return, or is deterred, creating standing. | Standing requires personal injury from barriers actually encountered or deterred future harm, not mere potential barriers. | Chapman lacks Article III standing on the record; remand to dismiss ADA claim. |
| Scope of standing to remove related barriers | One suit may remove all barriers related to Chapman's disability that he is likely to encounter. | Standing should be limited to barriers affecting Chapman or encountered barriers only. | Court prohibits expansion here; standing insufficient and relaunches dismissal; but affirms principle that encountered barriers may support related removals in theory. |
Key Cases Cited
- Doran v. 7-Eleven, Inc., 524 F.3d 1034 (9th Cir. 2008) (standing where deterrence or intent to return supports injunctive relief)
- Fortyune v. Am. Multi-Cinema, Inc., 364 F.3d 1075 (9th Cir. 2004) (real and immediate threat of repeated injury for injunctive relief)
- Pickern v. Holiday Quality Foods, Inc., 293 F.3d 1133 (9th Cir. 2002) (deterrence doctrine supports standing when barriers deter future access)
- Steger v. Franco, Inc., 228 F.3d 889 (8th Cir. 2000) (one suit may address barriers throughout a facility related to the plaintiff's disability)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (Supreme Court 1992) (standing requires concrete, particularized injury and causal connection)