Netflix

Donald Cullen v. Netflix

Good Law
600 F. App'x 508
United States Court of Appeals for the Ninth CircuitApril 1, 201513-15092California382 words

Opinion

Opinion

MEMORANDUM

Cullen appeals the district court’s dismissal of his California Disabled Persons Act claim, Cal. Civ.Code §§ 54, 54.1(a), his Unruh Civil Rights Act claim, Cal. Civ. Code §§ 51-52 , and his Unfair Competition Law claim, Cal. Bus. & Prof.Code § 17200. We have jurisdiction under 28 U.S.C. § 1291 , and we affirm.

Cullen’s Disabled Persons Act and Un-ruh Civil Rights Act claims are predicated on the Americans with Disabilities Act (“ADA”). See Cal. Civ.Code § 51(f) (“A violation of the right of any individual under the [ADA] shall also constitute a violation of this section.”); id. § 54(c) (same). Under Title III of the ADA, “[n]o individual shall be discriminated against on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place of public accommodation.” 42 U.S.C. § 12182 (a). We have previously interpreted the statutory term “place of public accommodation” to require “some connection between the good or service complained of and an actual physical place.” See Weyer v. Twentieth Century Fox Film Corp., 198 F.3d 1104, 1114 (9th Cir.2000). Because Netflix’s services are not connected…

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