Chapman v Pier 1 Imports Flashcards
Issue of Standing (19 cards)
What was the fundamental issue in Chapman v. Pier 1 Imports?
Whether Chapman had standing under Article III to seek injunctive relief for architectural barriers at Pier 1 Imports that he had not personally encountered.
What is the significance of Article III standing in ADA cases?
It ensures that a plaintiff demonstrates a real, personal injury or threat of injury related to their disability from noncompliant barriers.
What did the Ninth Circuit conclude about Chapman’s Article III standing?
Chapman lacked Article III standing because he failed to allege and prove a sufficient injury-in-fact linked to his disability.
How did the Ninth Circuit define an injury-in-fact in ADA cases?
An encounter with a barrier that interferes with the plaintiff’s full and equal enjoyment of a facility due to their specific disability.
What are the ADA Accessibility Guidelines (ADAAG)?
Technical standards required for public accommodations to be accessible to individuals with disabilities.
What role does the intent to return play in establishing standing under the ADA?
It demonstrates a real and immediate threat of future harm, allowing a plaintiff to seek injunctive relief.
Why was Chapman’s complaint considered jurisdictionally defective?
It failed to detail specific barriers encountered or explain how they were connected to his disability.
What does the ADA mandate regarding the removal of architectural barriers?
The removal of architectural barriers that hinder access to public accommodations unless such removal is not readily achievable.
Can an ADA plaintiff challenge barriers they have not encountered?
Yes, if they have standing based on barriers they have encountered and those unencountered barriers relate to their specific disability.
What does the deterrent effect doctrine imply in ADA litigation?
A disabled individual has standing if deterred from visiting a noncompliant public accommodation due to known accessibility barriers.
How did the court view a ‘formulaic recitation’ of the ADA violation elements?
As insufficient for establishing standing, requiring concrete allegations connecting specific barriers to the plaintiff’s disability.
What broader implications does the Chapman decision have for ADA compliance?
It emphasizes the need for plaintiffs to demonstrate tangible injuries related to their disability.
What was the deficiency in Chapman’s Accessibility Survey?
It merely listed purported ADA and CBC violations without tying them to Chapman’s specific disability.
What is the ‘personal stake’ requirement in ADA cases?
The plaintiff must demonstrate a personal injury-in-fact related to their specific disability.
How does the court ensure that ADA claims are not merely theoretical?
By requiring plaintiffs to show specific barriers that have affected or will affect their access due to their disability.
What reasoning did the court provide for vacating the district court’s decision?
Chapman failed to establish that he had suffered an injury-in-fact related to his disability.
What did the court say about the role of ‘piecemeal litigation’ in ADA compliance?
A rule limiting challenges to only encountered barriers would lead to piecemeal litigation, thwarting ADA’s goals.
How did the court view the relationship between plaintiffs and architectural barriers?
Plaintiffs must demonstrate how the barriers interfere with their specific disability to establish an injury-in-fact.
In what way did the court emphasize the specificity required in ADA complaints?
Complaints must specifically allege how particular barriers impact the plaintiff’s disability.
