Griffin v. Dep’t of Labor Fed. Credit Union (P)

A blind plaintiff lacks standing to sue the Department of Labor Federal Credit Union for failing to comply with the Americans with Disabilities Act, and the district court properly dismissed his claim on that basis. This case presents only the issue whether this plaintiff who is barred by law from making use of the defendant’s services may sue for an allegedly deficient website. The answer to this narrow question is no.

The plaintiff is not a member of the Credit Union, he is not eligible to become a member of the Credit Union, he has no plans to become eligible to be a member of the Credit Union, and no action the court takes could possibly make him eligible to become a member of the Credit Union. Under these specific circumstances there can be no injury in fact. The court does not consider whether a similarly disabled individual who was eligible for credit union membership would have standing.

Affirmed. Judge King wrote a concurring opinion.

Griffin v. Dep’t of Labor Fed. Credit Union (P), No. 18-1312, Jan. 3, 2019. 4th Cir. (Wilkinson) from EDVA at Alexandria (Ellis).



Categories: 4th U.S. Circuit Court of Appeals, Opinions, Published

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