Lieber v. Macy’s West, Inc. (1999)
- reannonrieder
- 2 days ago
- 2 min read
By: Leah O’Donohue
Overview
The case of Lieber v. Macy’s West, Inc. (1999) was a class-action lawsuit heard in the Northern District of California. The plaintiffs in this case were individuals with mobility disabilities alleging that the defendant, Macy’s West, Inc., was failing to comply with not only the Americans with Disabilities Act (“ADA”), but also several California accessibility laws. The plaintiffs claimed that several “barriers to access” within the retail store, such as inaccessible restrooms, fitting rooms, and aisles, constituted a breach of the ADA. The defendant's argument in this case was that they had already made reasonable efforts to remove any barriers, and as such, were in compliance with relevant accessibility laws [1].
Summary
The primary issue considered in this case was whether the removal of any of the barriers in the Macy’s was “readily achievable,” as required by the ADA [1].
According to the ADA’s Standards for Accessible Design, businesses are required to remove architectural barriers where readily achievable, meaning without much difficulty or expense. The amount of difficulty and expense required also scales with the size and resources available to said business, with large businesses being expected to do more than smaller businesses [2].
The plaintiffs presented extensive evidence of the aforementioned violations of the ADA, including evidence of improper spacing between the store’s displays, which limited accessibility for those with mobility issues. Through this evidence, the court found that both older areas of the store as well as areas that had recently undergone renovation failed to adhere to the ADA’s minimum width requirements of routes to fitting rooms and sales counters. Even temporary displays were found to often be obstructing pathways, despite being movable [1].
The defendant’s response to the evidence presented was that it had already invested a sufficient amount of resources into renovations, and that removing even more barriers would go beyond the “readily achievable” condition of the ADA [1].
The court ruled in favor of the plaintiffs in this case, ruling that Macy’s was in violation of the ADA as it had failed to make adequate efforts to comply with the ADA’s “readily achievable” standard. Additionally, the court noted that rearranging displays and making minor changes would be an easy remedy that would fall within the difficulty and expense required of a business of that size [1].
Impact
The decision in Lieber v. Macy’s West, Inc. reinforced the duty of retailers and other public spaces to take a proactive stance in identifying and removing barriers to accessibility where “readily achievable.” Compliance with the ADA and its Standards for Accessible Design requires continuous assessment and accommodation, not merely one-time renovations.
Court Documents
Lieber v. Macy’s West, Inc., 80 F.Supp.2d 1065 (N.D. Cal. 1999)
Citations
“Ada Standards for Accessible Design.” ADA.Gov, www.ada.gov/law-and-regs/design-standards/. Accessed 26 Jan. 2026.
