Richard Holland v. Good Wheels, 458 F. App'x 98

Holland and Cottrell, pro se plaintiffs, sued Good Wheels for disability-related retaliation, NJCLA, NJCRA, and false imprisonment; they advocate for disabled access and filed citizen complaints about improperly designated disability parking.
Holland alleged he shopped at Good Wheels and photographed improperly parked cars in 2006, and was verbally berated by a salesman, Fox, when leaving the premises.
The district court dismissed Cottrell for lack of standing but denied Good Wheels’ dismissal as to Holland; Holland and Good Wheels cross-moved for summary judgment.
In March 2011, the district court denied Holland’s summary judgment motion and granted summary judgment to Good Wheels on all claims, including retaliation and false imprisonment.
Holland sought reconsideration under Rule 59(e) and relief under Rule 60(b), which the district court denied; Holland timely appealed.
The appeal was summarily affirmed as presenting no substantial question.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Holland proved a prima facie retaliation claim under ADA/NJLAD.	Holland claims protected activity (citizen complaints) and adverse action (ban from premises) with causal link.	Good Wheels provided a nondiscriminatory reason for banning Holland; no pretext shown.	Yes, prima facie established; but no pretext proven; affirmed denial of retaliation claim.
Whether Good Wheels’ reasons were pretextual for the retaliation ban.	Evidence shows pretext via ongoing complaints and post-complaint conduct.	Evidence does not prove pretext; reasons were legitimate and nondiscriminatory.	District court did not abuse discretion; no pretext shown.
Whether false imprisonment claim survived summary judgment.	Holland was trapped on the premises without legal justification.	Holland could exit by driving around Fox’s car; not detained.	Summary judgment upheld; no detention with lack of legal authority.
Whether reconsideration and Rule 60(b) relief were appropriate.	New evidence and misapplication of standards warrant relief.	Post-submission events cannot be considered; no abuse of discretion.	No abuse; reconsideration and Rule 60(b) relief denied.

Saldana v. Kmart Corp., 260 F.3d 228 (3d Cir. 2001) (standard for summary judgment; burden on nonmovant)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (summary judgment standard; burden shifting)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework in discrimination cases)