DALTON v. SAINT BARNABAS MEDICAL CENTER, 2:21-cv-05354

Background:

Pro se plaintiff Robert C. Dalton, who alleges he has a traumatic brain injury (TBI), sued after a single ER visit to Saint Barnabas Medical Center (part of RWJBarnabas), claiming defendants denied his requested effective-communication accommodations.
Requested accommodations included: having NP Nicole Centrella record/tape her verbal explanations, moving to a quieter location and obtaining imaging, and permitting Dalton to audio-record clinicians using his phone.
Defendants: Barnabas Medical Center, RWJBarnabas Health, Nicole Centrella (NP) and Dr. Lauren Curato. Dalton asserted violations of Titles II and III of the ADA, Section 504 of the Rehabilitation Act, the Fifth and Fourteenth Amendments, and 42 C.F.R. §§ 482.2 and 482.24.
The Court granted Defendants’ motions in part: dismissed with prejudice Dalton’s claims against Dr. Curato and NP Centrella; dismissed with prejudice Dalton’s Title II and Title III ADA claims, constitutional claims, and the 42 C.F.R. claims as to Barnabas Medical Center and RWJBarnabas.
The Court allowed Section 504 Rehabilitation Act claims to proceed against Barnabas Medical Center and RWJBarnabas, and granted limited leave to amend only to plead claims raised for the first time in Dalton’s opposition briefs (deadline provided).

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of Title II ADA	Dalton alleged denial of effective-communication accommodations by healthcare defendants	Defendants argued Title II applies only to government actors	Dismissed — Title II does not apply to private hospital/providers
Title III ADA (public accommodation) — monetary relief & standing	Dalton sought damages and injunctive relief for discrimination by hospital system	Defendants argued Title III allows only prospective injunctive relief and Plaintiff lacks standing for injunctive relief	Dismissed as to Barnabas/RWJBarnabas for lack of standing to seek injunctive relief; damages unavailable under Title III
Individual liability under Title III	Dalton sued Centrella and Curato individually for Title III violations	Defendants argued individuals are not liable under Title III absent ownership/operation of facility	Dismissed — individuals not liable under Title III; complaint lacked allegations they owned/operated hospital
Section 504 Rehabilitation Act viability	Dalton alleged he is disabled, hospital receives federal funds, and was denied auxiliary aids	Defendants argued facts insufficient to state claim and damages require deliberate indifference proof	Survived as to Barnabas Medical Center and RWJBarnabas — pleadings plausibly state Section 504 claim; deliberate-indifference proof not required at dismissal stage
42 C.F.R. §§ 482.2 & 482.24 private right of action	Dalton invoked these federal hospital regulations	Defendants argued the regulations are conditions of participation and create no private cause of action	Dismissed — no private right of action under those regulations
Due Process/Equal Protection (constitutional claims)	Dalton contended his civil rights under Fifth/Fourteenth Amendments were violated	Defendants argued they are private actors, not state actors	Dismissed — constitutional claims require state action and were not pleaded
Leave to Amend	Dalton sought leave to file a second amended complaint, including claims raised in opposition	Defendants opposed as untimely, no proposed pleading provided	Limited leave granted to amend only for claims first raised in opposition; otherwise dismissals with prejudice stand

Key Cases Cited

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading plausibility and dismissal framework)
Emerson v. Thiel College, 296 F.3d 184 (individuals not liable under Title III absent ownership/operation)
Rendell-Baker v. Kohn, 457 U.S. 830 (Fourteenth Amendment requires state action)
Bowers v. Nat'l Collegiate Athletic Ass'n, 346 F.3d 402 (Title III remedies limited to injunctive relief)
Barnes v. Gorman, 536 U.S. 181 (punitive damages not available under Rehabilitation Act)
Ridley School Dist. v. M.R., 680 F.3d 260 (elements for a Rehabilitation Act §504 claim)
Santiago v. Warminster Twp., 629 F.3d 121 (Third Circuit three-part pleading inquiry)