Sepulveda v. Rosa Madera LLC
2:24-cv-03060
| E.D. Cal. | May 29, 2025Background
- Plaintiff Richard Sepulveda, who has mobility impairments and uses a walker, alleges accessibility barriers at defendant’s restaurant (Rosa Madera Sabores de Mexico) in Sacramento, CA.
- Plaintiff asserts the restaurant’s restrooms and dining tables are noncompliant with the ADA Accessibility Guidelines, preventing his full access.
- Alleged injuries include insufficient space under restroom sinks and dining tables, deterring him from returning to the restaurant.
- Sepulveda filed claims under the Americans with Disabilities Act (ADA), Unruh Civil Rights Act, California Disabled Persons Act, and California Health & Safety Code.
- Defendant, El Puesto EG, LLC, moved to dismiss the complaint for lack of subject-matter jurisdiction under Rule 12(b)(1), claiming insufficient, conclusory allegations and questioning standing.
- The court must determine if the plaintiff has Article III standing based on the adequacy of alleged barriers related to his disability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Article III Standing under ADA | Sepulveda was deterred by ADA violations relating to his disability. | Allegations too vague; only states difficulty, not specific ADAAG violations. | Plaintiff alleged sufficient facts to establish standing. |
| Sufficiency of Allegations | Barriers encountered relate directly to plaintiff's use of walker and disabilities. | Complaint is conclusory; should specify type of walker and detailed barriers. | Level of detail provided is adequate under the law. |
| Standing for State Law Claims | State claims are satisfied if ADA violation is properly alleged. | State standing independently insufficient; urges court to decline jurisdiction. | ADA violation supports standing for state claims. |
| Supplemental Jurisdiction | Court should retain supplemental jurisdiction over state law claims. | Cites concerns over frequent filers and forum-shopping. | Declined to reject jurisdiction; retains case. |
Key Cases Cited
- Spokeo, Inc. v. Robins, 578 U.S. 330 (standing requires clear allegation of injury in fact)
- Chapman v. Pier 1 Imps. (U.S.) Inc., 631 F.3d 939 (ADA standing does not require total exclusion but interference with full and equal enjoyment)
- TransUnion LLC v. Ramirez, 594 U.S. 413 (sets out requirements for Article III standing)
- White v. Lee, 227 F.3d 1214 (standing challenges are proper under Rule 12(b)(1))