Woods v. Kasztl Walsh, LLC is a recent case that highlights the importance of establishing standing to seek injunctive relief under the Americans with Disabilities Act (ADA). The plaintiff in this case sued an inaccessible apartment complex for ADA Title III, NYSHRL, and NYCHRL violations. However, the court dismissed the ADA claim, citing the plaintiff's vague and conclusory allegations of wanting to return to the subject location.
The court explained that to establish standing, a plaintiff must show a past injury under the ADA, a reasonable inference that the discriminatory treatment will continue, and a real and immediate threat of future injury based on concrete plans to return to the subject location. The plaintiff's "someday intentions" of wanting to return are not sufficient to establish standing.
In conclusion, Woods v. Kasztl Walsh, LLC highlights the importance of understanding and meeting the ADA standing requirements when filing a claim. Plaintiffs must provide specific and concrete plans to return to the subject location to establish a real and immediate threat of future injury. This case serves as a reminder that vague and conclusory allegations are not enough to establish standing under the ADA.