900 F.3d 1007
8th Cir.2018Background
- Plaintiff Zach Hillesheim, a wheelchair user, visited a Holiday Stationstores location and identified three alleged accessibility defects: (1) two accessible parking spaces lacked vertical signage, (2) one accessible space lacked an adjacent access aisle, and (3) a garbage can obstructed the curb ramp into the store.
- Holiday inspected and remedied the defects after Hillesheim filed suit: it removed the space lacking an access aisle, installed ADA-compliant vertical signage at the remaining accessible space, and removed the garbage can.
- Hillesheim sued in Minnesota state court alleging ADA and Minnesota Human Rights Act (MHRA) violations; Holiday removed the case to federal court. After discovery, Holiday moved for summary judgment on subject-matter-jurisdiction grounds.
- Hillesheim conceded his ADA claims were moot due to Holiday’s remedial actions but maintained his MHRA claims and sought remand of state-law claims if federal jurisdiction was absent.
- The district court granted summary judgment and dismissed the MHRA claims with prejudice for lack of Article III standing. The Eighth Circuit reviews standing de novo and evaluates whether Hillesheim produced evidence at summary judgment showing injury-in-fact for each asserted defect.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hillesheim had Article III injury-in-fact from lack of an access aisle | Hillesheim asserted the ADA violation deterred him from visiting and thus injured him | Holiday argued Hillesheim offered no evidence tying the access-aisle absence to a concrete injury | No standing shown; dismissal for lack of federal jurisdiction required remand to state court rather than dismissal with prejudice |
| Whether Hillesheim had Article III injury-in-fact from lack of vertical signage | Hillesheim claimed inadequate vertical signage injured him by deterring access | Holiday argued no evidence that signage deficiency caused a concrete, particularized injury | No standing shown; remand to state court required |
| Whether Hillesheim had Article III injury-in-fact from garbage can blocking curb ramp | Hillesheim’s declaration described being unable to safely navigate the ramp and thus leaving the store | Holiday contended evidence (photograph) showed adequate space and no concrete injury | Standing established: declaration tied the garbage can placement to Hillesheim’s decision not to enter; claim survives for district court to consider jurisdictional discretion |
| Whether the district court properly dismissed state-law claims with prejudice after finding lack of federal jurisdiction | Hillesheim urged remand of state-law claims to state court | Holiday supported dismissal on merits for lack of jurisdiction | Court erred: when federal jurisdiction is lacking post-removal, claims must be remanded under 28 U.S.C. § 1447(c); two claims vacated and remanded to state court |
Key Cases Cited
- Park v. Forest Serv. of the U.S., 205 F.3d 1034 (8th Cir.) (standard of de novo review for standing)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (Article III injury-in-fact requirement: concrete and particularized)
- Hughes v. City of Cedar Rapids, 840 F.3d 987 (8th Cir.) (federal standing required to pursue state-law claims in federal court)
- Braitberg v. Charter Commc’ns, Inc., 836 F.3d 925 (8th Cir.) (mere allegation of statutory violation insufficient for standing)
- Scott v. Harris, 550 U.S. 372 (2007) (photographic evidence can be conclusive in rare cases, but courts must draw inferences for nonmoving party at summary judgment)
- Brown v. Mortg. Elec. Registration Sys., Inc., 738 F.3d 926 (8th Cir.) (district court’s discretion under § 1367 to decline supplemental jurisdiction after federal claims dismissed)
- Disability Support All. v. Heartwood Enters., LLC, 885 F.3d 543 (8th Cir.) (plaintiff need not physically attempt access to establish standing when concrete injury shown)