Federal Court in California Rejects “Non-Dairy Milk” Discrimination Claim
California restaurants, as places of public accommodation, bear a legal duty to serve all customers equitably, which includes providing reasonable accommodations for individuals with disabilities. Similarly, employers in California are required to accommodate their employees’ disabilities to ensure fair and equal treatment in the workplace. When these duties are ignored, the courts often become the avenue for enforcing compliance. This principle was highlighted recently in a federal case in California, where a woman challenged a surcharge for non-dairy alternatives in coffee beverages. This case underscores how the boundaries of reasonable accommodations are being tested in various contexts, including public accommodations and employment settings.
The Facts
The plaintiff in the case, alongside other class members, alleged that Peet’s Coffee’s practice of charging extra for non-dairy alternatives such as oat milk, soy milk, or almond milk discriminated against those with lactose intolerance or milk allergies. Their claims were grounded in multiple legal frameworks, including the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act, among others. While Peet’s did offer non-dairy options, the plaintiffs argued that imposing an additional cost constituted discrimination against individuals whose medical conditions necessitated such substitutions.
Peet’s sought to dismiss the case, contending that charging for non-dairy alternatives was not discriminatory under the ADA. The court’s analysis turned on two main points: whether the surcharge constituted a discriminatory practice and whether the plaintiffs had requested reasonable modifications to the pricing policy. The court noted that the ADA does not require businesses to alter their standard offerings to provide special goods or services but only mandates nondiscriminatory access to what is provided. Since Peet’s non-dairy surcharge applied to all customers—not just those with disabilities—the court found no violation of the ADA’s provisions against surcharges.
Further, the court examined whether Peet’s refusal to waive the surcharge amounted to a failure to make reasonable modifications under the ADA. For a modification to be deemed reasonable and necessary, plaintiffs must demonstrate that its absence deprives them of an equivalent experience. In this case, the plaintiffs failed to establish that such a request had been made or that the surcharge significantly impeded their access to Peet’s goods and services. Consequently, the court dismissed the complaint, concluding that the claim did not rise to the level of actionable discrimination under federal or state law.
The Takeaway
This ruling highlights the complexity of disability accommodations in both public and employment settings. While the ADA and similar laws are robust in protecting individuals with disabilities, they do not mandate accommodations that extend beyond what is reasonable. For example, in employment contexts, employers are required to provide accommodations that enable employees to perform their essential job functions, but these accommodations must not impose an undue burden on the employer. Similarly, in public accommodations, businesses are not obligated to fundamentally alter their operations to cater to specific preferences, even when linked to a disability.
The court’s decision reflects a growing tension in disability law: how to balance the expanding scope of protections with practical limitations. In the employment context, this balance often involves determining whether an accommodation is feasible or whether it poses an undue hardship. For employees facing discrimination based on disability, race, gender, or other protected characteristics, it’s essential to seek experienced legal counsel to assess the strength of their claims and identify the best course of action.
Have You Experienced Workplace Discrimination?
If you believe you’ve been a victim of employment discrimination, whether due to disability or another protected status, contact the Hardin Law Group. Our California employment law attorneys are dedicated to protecting employees’ rights and holding employers accountable for unlawful practices. With a deep understanding of state and federal employment laws, we’ll help you navigate the complexities of your case and fight for the justice you deserve. Call us today at (949) 337-4810 for a free consultation. Let us stand by your side and ensure your rights are upheld.