Ramos v. Pistiolas
2:24-cv-02117
| E.D. Cal. | Apr 22, 2025Background
- Plaintiff Oscar Ramos sued Little Knopp Bakery, owned by Stavroula Pistiolas, alleging violations of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act due to physical barriers at the bakery.
- Alleged barriers included improper accessible parking, inaccessible service counter, and narrow interior aisles.
- After the lawsuit was filed, Defendant remediated all identified accessibility barriers, as confirmed by both parties and their experts.
- Plaintiff sought injunctive relief, statutory damages, interest, attorney’s fees, and costs; Defendant moved to dismiss, arguing the ADA claim was moot due to remediation.
- Plaintiff raised concerns about potential recurrence of violations and argued for continuing federal jurisdiction over state law claims even if the ADA claim was dismissed.
- The court determined all barriers had been remedied, there was no reasonable expectation of recurrence, so the ADA claim was moot; the state law claims were dismissed without prejudice to refiling in state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of ADA Claim | Barriers could recur; injunction still appropriate | All barriers remedied; no live controversy remains | ADA claim is moot |
| Voluntary Cessation Exception | Defendant might not comply in the future due to ease of reconfiguration | Bona fide intent to comply shown; structural fixes made | No reasonable expectation of recurrence |
| Supplemental Jurisdiction Over State Claims | Should retain jurisdiction over Unruh Act claim | Should decline as ADA claim (federal anchor) is moot | Court declines supplemental jurisdiction |
| Judicial Economy in Retaining Case | Retain for efficiency, as in some prior cases | No merits decision yet; little economy served | No judicial economy; dismiss state law claims |
Key Cases Cited
- Wander v. Kaus, 304 F.3d 856 (9th Cir. 2002) (only injunctive relief is available under ADA Title III)
- Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., 528 U.S. 167 (2000) (voluntary cessation exception to mootness doctrine)
- Kearns v. Ford Motor Co., 567 F.3d 1120 (9th Cir. 2009) (mootness exists when no live controversy remains)
- Ruvalcaba v. City of Los Angeles, 167 F.3d 514 (9th Cir. 1999) (claims must be dismissed if no relief is possible)
- Arroyo v. Rosas, 19 F.4th 1202 (9th Cir. 2021) (judicial economy in retaining jurisdiction over state claims after ADA summary judgment)
- Vo v. Choi, 49 F.4th 1167 (9th Cir. 2022) (affirmed declining supplemental jurisdiction over state law claims early in litigation)