Miraglia v. Bd. of Supervisors of the La. State Museum
901 F.3d 565
| 5th Cir. | 2018Background
- Miraglia, a quadriplegic who uses a power wheelchair, sued the Louisiana State Museum (the Museum) under Title II of the ADA and §504 of the Rehabilitation Act after he could not access retail storefronts in the historic Lower Pontalba Building. He sought injunctive/declaratory relief, monetary damages, and attorneys’ fees.
- The Museum owns and preserves the historic building but leases retail spaces to tenants; portions of the building are historic and alterations are constrained.
- Experts for both sides ultimately agreed that five-foot portable ramps and door buzzers would reasonably accommodate access without altering historic character; days before trial the Museum purchased ramps, buzzers, and signage and represented it would implement them.
- The bench trial court found equitable claims moot (while retaining jurisdiction to ensure compliance), awarded Miraglia $500 in emotional damages, and granted $30,050.35 in attorneys’ fees.
- On appeal Miraglia challenged mootness dismissal; the Museum appealed the damages and fee awards. The Fifth Circuit dismissed Miraglia’s appeal as moot, reversed the damages award for failure to find intent, and affirmed the fee award because Miraglia was a prevailing party due to the court’s retention of jurisdiction and implementation oversight.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of equitable relief | Case not moot because court should enjoin Museum to ensure tenant compliance and add lease provisions | Museum implemented ramps/buzzers/signage and already has lease clauses requiring legal compliance; representations and implementation moot the equitable claims | Dismissed as moot — Museum implemented relief and court retained jurisdiction to ensure compliance, so no live equitable controversy |
| Requirement and proof of intent for monetary damages | Miraglia argued intent not required (disparate impact) or that evidence showed intent | Museum argued intent is required for damages and Miraglia failed to prove it | Reversed damages — plaintiff must prove intentional discrimination for money damages and record lacked findings/evidence of notice/intent |
| Waiver of intent defense | Miraglia contended Museum waived intent defense by omission from pretrial order and not arguing below | Museum relied on bench-trial precedent that sufficiency of evidence on elements need not be raised below; pretrial omission does not equal stipulation | Museum did not waive the argument; court may review sufficiency of bench-trial evidence on appeal |
| Entitlement to attorneys’ fees (prevailing party) | Miraglia claimed prevailing-party status based on implemented relief and court oversight | Museum argued reversal of damages means Miraglia is not prevailing and fees are excessive | Affirmed fees — Miraglia is prevailing because judicial imprimatur (court retained jurisdiction/oversight) materially changed legal relationship; district court's lodestar/reduction analysis not abused |
Key Cases Cited
- Staley v. Harris Cty., 485 F.3d 305 (5th Cir. 2007) (post-judgment events can render claims moot)
- Sossamon v. Lone Star State of Tex., 560 F.3d 316 (5th Cir. 2009) (government assurances of compliance reduce applicability of voluntary-cessation exception)
- United States v. Georgia, 546 U.S. 151 (U.S. 2006) (recognizing private damages actions under Title II where appropriate)
- Delano-Pyle v. Victoria Cty., 302 F.3d 567 (5th Cir. 2002) (money damages under ADA/RA require intentional discrimination)
- Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Human Res., 532 U.S. 598 (U.S. 2001) (attorney-fee awards require judicial imprimatur; consent decrees and court-ordered oversight qualify)