The Ninth Circuit Court of Appeals has reversed a lower court's decision that denied attorney fees to LaSandra Price, a plaintiff in an Americans with Disabilities Act (ADA) case against Family Dollar. This ruling, filed on July 13, 2026, affects individuals seeking to enforce their rights under the ADA, particularly those who require accessible facilities.
LaSandra Price, who has Parkinson's disease and uses a wheelchair, filed a lawsuit against Family Dollar #8920 and its owner, Wael Diab, after encountering accessibility issues at the store. The case highlights the ongoing struggle for compliance with the ADA, which mandates that public accommodations be accessible to individuals with disabilities.
The dispute began when Price visited the Family Dollar store multiple times in 2021 and encountered barriers such as poorly marked disabled parking spaces and narrow aisles. After the defendants failed to respond to her complaint, the court entered a default judgment in her favor, ordering the store to make necessary accessibility improvements. However, when Price sought attorney fees for her legal efforts, the district court denied her request, claiming she was not a prevailing party because the injunction merely required the defendants to comply with existing federal law.
The case reached the Ninth Circuit after Price appealed the district court's decision. The appellate court's ruling emphasized that a plaintiff can be considered a prevailing party under the ADA if they obtain actual relief that materially alters the legal relationship between the parties. The court stated, "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." This clarification is crucial for future ADA cases, as it affirms that obtaining injunctive relief is sufficient for prevailing party status, even if the relief aligns with existing legal obligations.
The Ninth Circuit's ruling reversed the district court's decision and remanded the case for further proceedings regarding the attorney fees. The appellate court noted that the district court had misinterpreted previous case law, particularly the case of Fischer v. SJB-P.D. Inc., which established that a plaintiff can prevail even when the relief obtained is not monetary. The court further explained that the district court's reasoning could undermine the enforcement of ADA rights, as it suggested that any injunctive relief would not confer prevailing party status.
Going forward, this ruling sets an important precedent for individuals with disabilities seeking to enforce their rights under the ADA. It clarifies that obtaining a court order for compliance with the ADA constitutes a significant victory, allowing plaintiffs to recover attorney fees for their efforts. This decision may encourage more individuals to pursue legal action against businesses that fail to comply with accessibility standards.
The Ninth Circuit's decision also highlights the importance of legal representation in ADA cases, as it underscores the need for attorneys to provide accurate and diligent work when filing fee motions. The court noted that the district court had raised concerns about the quality of Price's attorney's fee petition, which included errors and seemed to be recycled from a previous case. While the appellate court did not rule on the specific amount of fees to be awarded, it emphasized that the district court should consider the quality of representation when determining a reasonable fee.
As the case moves back to the district court, it remains to be seen how the judge will address the concerns raised by the Ninth Circuit regarding the attorney fees. Price's case serves as a reminder of the ongoing challenges faced by individuals with disabilities in accessing public spaces and the importance of legal mechanisms to enforce their rights.
In conclusion, the Ninth Circuit's ruling in Price v. Diab reinforces the rights of individuals with disabilities under the ADA and clarifies the criteria for prevailing party status in cases involving injunctive relief. This decision not only impacts Price but also sets a precedent that may benefit others seeking to ensure compliance with accessibility laws in the future.