Does a plaintiff have standing to sue for injunctive relief against a noncompliant facility?

"Even if he is not deterred from returning to the public accommodation at issue," a plaintiff has standing to sue for injunctive relief when he has demonstrated an "injury-in-fact coupled with an intent to return to a noncompliant facility." Chapman, 631 F.3d at 944. "It is well settled that a plaintiff need not 'await the consummation of threatened injury to obtain prospective relief.'" Id. at 950 (quoting Farmer v. Brennan, 511 U.S. 825, 845 (1994) (additional

Page 8

citations omitted)). Instead, standing "requires a sufficient showing of likely injury in the future related to plaintiff's disability," based on a court's finding "it is reasonable to infer" plaintiff intends to return to the same premises in the future. Id. at 949 (citing Camarillo v. Carrols Corp., 518 F.3d 153 (2d Cir. 2008)).