Law School Case Brief
Aikins v. St. Helena Hosp. - 843 F. Supp. 1329 (N.D. Cal. 1994)
There is a three-part test for standing, a constitutional prerequisite growing out of Article III's "case or controversy" requirement. U.S. Const. art. I, § 2, cl. 1. The first prong of the test is the "injury in fact" requirement: The plaintiff must have suffered an "injury in fact"—an invasion of a legally-protected interest, which is (a) concrete and particularized; and (b) actual or imminent, not conjectural or hypothetical. The second and third elements of the test are causation and redressability.
Plaintiff Elaine Aikins was a deaf woman whose husband, Harvey Aikins, suffered a massive cardiac arrest. Paramedics transported Mr. Aikins to defendant St. Helena Hospital ("Hospital"). At the Hospital, defendant Dr. James Lies, M.D., an independent contractor, decided to perform an emergency angioplasty on Mr. Aikins. He attempted to consult Mrs. Aikins and to obtain her consent, but Mrs. Aikins could not understand him and requested that interpreters be provided. The Hospital was not able to provide any. During the course of Mr. Aikins' stay at the Hospital, Mrs. Aikins repeatedly requested for interpreter services, but the Hospital did not provide one. Subsequently, Mrs. Aikins' daughter arrived at the Hospital and participated in a meeting with Dr. Lies and Mrs. Aikins. Mrs. Aikins claimed that this meeting was the first opportunity that she had to communicate directly with Dr. Lies and to receive complete answers to her questions. As a result of the meeting, Mrs. Aikins requested that her husband's life support be discontinued. Mr. Aikins died two days later. Later, Mrs. Aikins and plaintiff California Association of the Deaf ("CAD") filed a lawsuit in federal district court against the Hospital and Dr. Lies under the Americans with Disabilities Act ("ADA"), the Rehabilitation Act of 1973, and various California civil rights statutes. Defendants filed motions to dismiss or, in the alternative, for summary judgment. Defendants also sought to have CAD dismissed from the lawsuit on the basis that CAD lacked standing.
(1) Did Mrs. Alkins and CAD have standing to seek injunctive relief? (2) Did defendants fail to comply with the ADA and the Rehabilitation Act of 1973 as a matter of law?
(1) No; (2) Yes.
The court granted in part and denied in part defendants' motions to dismiss and for summary judgment. Applying the applicable three-prong test, the court held that neither CAD nor Mrs. Aikins had standing to seek injunctive relief. The court noted that a plaintiff seeking injunctive relief premised upon an alleged past wrong must demonstrate a "real and immediate threat" of repeated future harm to satisfy the injury in fact prong of the standing test. The court held that Mrs. Aikins failed to show a "real and immediate threat" of repeated future harm. The court averred that CAD's standing to seek injunctive relief suffered from the same defects. According to the Court, an association seeking to bring suit on behalf of its members must show: (1) that its members would have standing to sue in their own right; (2) that the interests that it was seeking to protect were germane to the organization's purpose; and (3) that neither the claim asserted nor the relief requested required the participation of individual members. CAD failed to show that its members would have standing to sue in their own right.
As to the second issue, the court held that there was a genuine dispute as to the issue of whether the Hospital complied with the ADA requirement to provide auxiliary aids. The record did not reveal that it complied with the ADA as a matter of law. The Hospital failed to demonstrate that it communicated effectively with Mrs. Aikins during her husband's stay in the Hospital. The court further held that Mrs. Aikins made a claim under the Rehabilitation Act against both the Hospital and the Dr. Lies, and that the neither had shown that they tried to comply with the Rehabilitation Act as a matter of law. Regarding damages, the court concluded that Mrs. Aikins was not entitled to compensatory relief under the ADA because her claim was dismissed for lack of standing; however, damages were available for violations of the Rehabilitation Act pursuant to § 794a of that Act, 42 U.S.C.S. § 794a.
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