{"id":421,"date":"2026-01-07T12:00:00","date_gmt":"2026-01-07T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=421"},"modified":"2026-01-07T12:00:00","modified_gmt":"2026-01-07T12:00:00","slug":"blomqvist-extra-space-storage-ada-title-iii-screening-injunction","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=421","title":{"rendered":"Bl\u00f6mqvist v. Extra Space Storage \u2014 N.D. Cal. screens ADA Title III storage-unit access claim past \u00a7 1915 but denies preliminary injunction"},"content":{"rendered":"
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Case<\/dt>\n
Logan Dakota Kai Bl\u00f6mqvist, et al. v. Extra Space Storage, Inc., et al.<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Northern District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-07<\/dd>\n
Docket No.<\/dt>\n
5:25-cv-07867<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
28 U.S.C. \u00a7 1915(e)(2) screening; 42 U.S.C. \u00a7 1983 state-action requirement; ADA Title III (42 U.S.C. \u00a7 12181); ADA retaliation (42 U.S.C. \u00a7 12203); preliminary injunction; Winter v. Natural Resources Defense Council<\/em>; storage facility access dispute<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Logan Dakota Kai Bl\u00f6mqvist and Todd Myers, proceeding pro se, sued Extra Space Storage, Inc. and related defendants alleging that they were being denied access to their respective storage units in Campbell and Los Gatos, California. They alleged the denial violated their leases and constituted discrimination on the basis of race and disability. They proceeded in forma pauperis and filed multiple TRO\/preliminary injunction applications seeking immediate, unrestricted access to their units and email-only communications.<\/p>\n

The court had previously screened an earlier version of the complaint, dismissed the \u00a7 1983 claim because Plaintiffs failed to allege joint action between the storage company and police, denied IFP-stage TRO relief, and granted leave to amend. Plaintiffs filed an amended complaint asserting three federal causes of action under \u00a7 1983, ADA Title III (42 U.S.C. \u00a7 12181), and ADA retaliation (42 U.S.C. \u00a7 12203), plus various state-law theories. They also filed a renewed TRO application that the court converted into a motion for preliminary injunction.<\/p>\n

The Court’s Holding<\/h2>\n

The court screened the amended complaint under 28 U.S.C. \u00a7 1915(e)(2) and found that it states at least one cognizable claim \u2014 sufficient to satisfy IFP screening \u2014 but it dismissed the \u00a7 1983 claim and denied the preliminary injunction.<\/p>\n

On the \u00a7 1983 claim, the court reaffirmed its earlier ruling that Plaintiffs had not pleaded the joint action with state actors that the statute requires. The amended complaint omitted the prior admissions that Plaintiffs themselves had repeatedly requested police presence, and instead alleged that \u201c[p]olice assistance\/refusal enabling a private lockout constitutes state action.\u201d That conclusory allegation does not establish an agreement or meeting of the minds between Extra Space and the police, as required by Fonda v. Gray<\/em>. The \u00a7 1983 claim was dismissed with what the court flagged as Plaintiffs\u2019 final opportunity to amend.<\/p>\n

On ADA Title III, however, the court \u2014 construing the pro se complaint liberally \u2014 found Plaintiffs adequately alleged a cognizable claim against the storage facility, which qualifies as a place of public accommodation. The ADA retaliation theory under \u00a7 12203 also survived screening. The court ordered service of the amended complaint on Extra Space.<\/p>\n

On the preliminary injunction, the court applied the demanding Winter v. Natural Resources Defense Council<\/em> standard. Plaintiffs failed to demonstrate a likelihood of success on the merits sufficient to support extraordinary preliminary relief, particularly given the procedural posture (defendants had not yet appeared and the screening process was just complete) and the questions about the strength of the disability-discrimination theory at this early stage. The motion was denied without prejudice to renewal once the case is more fully developed.<\/p>\n

Key Takeaways<\/h2>\n