Analysis of Architectural Barrier Cases Under ADA Title III: Case Law
- Corey Taylor
- Apr 26
- 3 min read
Overview of Key Legal Principles
Title III of the Americans with Disabilities Act (ADA) mandates that places of public accommodation remove architectural barriers where readily achievable or provide accessible alternatives. Courts have developed critical frameworks for analyzing these claims, particularly regarding burden-shifting, standing, and compliance standards. Below is an analysis of seminal ADA case law, interpreting these requirements.
Burden-Shifting Framework for Barrier Removal
Lopez v. Catalina Channel Express, Inc. (9th Cir. 2020)
Barrier: A wheelchair user could not access a ferry restroom due to a narrow door.
Holding: The Ninth Circuit established a burden-shifting framework:
1. The plaintiff must plausibly show that barrier removal is readily achievable (i.e., costs do not exceed benefits).
2. If met, the burden shifts to the defendant to disprove feasibility.
3. Courts weigh factors under 42 U.S.C. § 12181(9), including cost, resources, and operational impact.
ADA Citation: 2010 ADA Standards, Section 404.2.5 (door clearances) and Section 303.4 (changes in level).
This decision clarified plaintiffs’ initial obligation to propose actionable solutions, even in complex contexts like maritime vessels.
Standing and Scope of Claims
Doran v. 7-Eleven, Inc. (9th Cir. 2008)
Barrier: Multiple accessibility issues in a convenience store, including narrow aisles and inaccessible restrooms.
Holding: Plaintiffs have standing to challenge all barriers at a location, even those not personally encountered, if deterred from visiting due to known barriers.
ADA Citation: 2010 ADA Standards, Section 208.2 (parking) and Section 604 (toilet compartments).
The court emphasized that deterrence itself constitutes an injury, allowing plaintiffs to identify barriers through expert inspections post-filing.
Alternative Methods of Access
Snyder v. Lady Slings the Booze, LLC (W.D. Ky. 2014)
Barrier: A 4-inch step at a bar entrance without a compliant ramp.
Holding: Even if barrier removal is not readily achievable (e.g., permanent ramp installation), businesses must provide alternative methods (e.g., portable ramps or staff assistance).
ADA Citation: 2010 ADA Standards, Section 303.4 (ramps for changes in level >½") and Section 405.2 (slope requirements).
The court rejected the defendant’s reliance on human assistance alone, ruling portable ramps were a readily achievable alternative.
Parking and Path of Travel Obligations
Wright v. RL Liquor (8th Cir. 2018)
Barrier: Non-compliant parking lot slopes and counter heights.
Holding: Plaintiffs must present specific evidence of readily achievable solutions. Mere allegations of non-compliance are insufficient.
ADA Citation: 2010 ADA Standards, Section 502 (parking) and Section 904.4 (counter heights).
The Eighth Circuit affirmed dismissal where the plaintiff failed to propose plausible remediation methods.
Pleading Requirements
Oliver v. Ralphs Grocery Co. (9th Cir. 2011)
Barrier: 18 alleged violations, including inaccessible aisles and checkout counters.
Holding: Plaintiffs must specify all barriers in their complaint. Barriers identified later via expert reports are inadmissible if not pleaded initially.
ADA Citation: 2010 ADA Standards, Section 403.5 (aisle width) and Section 904.3 (checkout counters).
This ruling imposed strict pleading standards to prevent "drive-by" lawsuits and ensure defendants receive fair notice.
Small Business Compliance
Deutsh v. Richard Watson Ins. Agency (W.D. La. 2015)
Barrier: Lack of van-accessible parking and ramps at an insurance office.
Holding: Default judgment granted against small businesses that fail to respond to claims, emphasizing strict liability for non-compliance.
ADA Citation: 2010 ADA Standards, Section 208.2.4 (van-accessible spaces) and Section 405 (ramp specifications).
The case highlights risks for entities ignoring ADA obligations, regardless of size.
DISCLAIMER: The information provided in this post is for informational purposes only and does not constitute legal advice. Please consult a qualified attorney for advice tailored to your situation.
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