Facts

Plaintiff, Summit Coastal Living, Inc., an addiction treatment center, filed suit for disability discrimination after the City of Costa Mesa enacted Ordinances 15-11 and 17-05 in order to regulate the rapidly growing sober living industry within the city.

PLAINTIFF'S CONTENTIONS: Plaintiff claimed that the City's Ordinances were discriminatory under the Federal Fair Housing Act, Americans with Disabilities Act, California Fair Employment and Housing Act, Rehabilitation Act, Civil Rights Act and California Government Code sections 11135 and 65008, because the City denied plaintiff's Conditional Use Permit and reasonable accommodation applications to allow plaintiff to bypass the occupancy limits as well as the 650 feet separation requirement for two of plaintiff's properties. Plaintiff's argument hinged on the notion that recovering addicts were classified as disabled.

DEFENDANT'S CONTENTIONS: Defendant denied all claims that the City's Ordinances were discriminatory or that the City had acted inappropriately in any way.

The City argued, among others, that there is no per se rule that states all individuals in a drug or alcohol rehabilitation program automatically qualify as disabled for purposes of the FHA, ADA, and similar discrimination statutes. The City further argued that plaintiff must prove on a case-by-case basis that its clients suffered from an impairment that substantially limits a major life activity, had a record of such impairment, or were regarded as having such an impairment.

Result

The court granted defendant City of Costa Mesa's motion for summary judgment because it found that plaintiff provided no evidence to support that any of its clients qualified as disabled.

Other Information

The judgment was the third ruling in favor of the City on its motions for summary judgment in seven federal actions that the City is currently engaged in.