Marsh v. Edwards Theatres Circuit, Inc

In Marsh v. Edwards Theatres Circuit, Inc. (1976) 64 Cal.App.3d 881, the wheelchair-bound plaintiff sought an award of damages and injunctive relief under the Unruh Civil Rights Act, alleging that he was improperly denied access to a movie theater. (Marsh v. Edwards Theatres Circuit, Inc., supra, 64 Cal.App.3d at pp. 884-889.) The appellate court concluded that the plaintiff could assert a claim solely under the DPA because only that statute specifically addressed disability discrimination, and the Unruh Civil Rights Act then contained substantive limitations rendering it "of little aid" to the plaintiff. (Marsh v. Edwards Theatres Circuit, Inc., supra, at pp. 889-891.)