(A successor in interest does not have standing to bring an ADA claim for injunctive relief in federal court. (City of Los Angeles v. Lyons (1983) 461 U.S. 95, 101.) However, the opposite rule applies in California state court since CCP 377.20, 377.30 provide that a cause of action is not lost by reason of the plaintiff’s death but instead it passes to the decedent’s successor in interest. Since the defendant’s restaurant was not physically altered after plaintiff’s wife’s death from complications suffered by a fall on stairs in the restaurant, plaintiff had a viable claim for injunctive relief under the ADA for removal of that barrier to access by the disabled.)