Background
LaSandra Price, who uses a wheelchair due to Parkinson’s disease, sued Family Dollar and its owner Wael Diab for ADA violations after encountering accessibility barriers at a Fontana store. The district court granted a default judgment and issued an injunction ordering the defendants to make specific accessibility improvements. However, the district court denied Price’s motion for attorney’s fees, ruling she was not a prevailing party because the injunction only required the defendants to comply with existing federal law.
The court’s reasoning
The Ninth Circuit held that under the Americans with Disabilities Act, a plaintiff prevails when actual relief on the merits materially alters the legal relationship between the parties by modifying the defendant’s behavior in a way that directly benefits the plaintiff. The court explained that an injunction constitutes a judicially enforceable order that subjects the defendant to further enforcement, thereby altering the legal relationship even if the underlying duty to comply with the law already existed. The court found the district court misread Ninth Circuit precedent in Fischer v. SJB-P.D. Inc., which established that a plaintiff can be a prevailing party based exclusively on injunctive relief without monetary damages.
A plaintiff prevails when actual relief on the merits of her claim materially alters the legal relationship between the parties by modifying the defendant’s behavior in a way that directly benefits the plaintiff.
Farrar v. Hobby, 506 U.S. 103, 111-12 (1992)
What it means going forward
Businesses facing ADA lawsuits that result in injunctive relief can no longer argue that such relief fails to confer prevailing party status simply because it mandates compliance with existing law. This ensures that plaintiffs who secure enforceable court orders for accessibility improvements are eligible to recover reasonable attorney’s fees.