has not established a likelihood of future injury, and thus, lacks standing to pursue injunctive relief under the ADA. i. Proximity of Public Accommodation As the distance between the plaintiffs residence and the public accommodation increases, the likelihood of future harm decreases. When the distance between the two is significant, especially if it is in excess of 100 miles, courts have consistently held that it weighs against finding a reasonable likelihood of future harm. E.g., Molski v. Levon Inv., No. C03-8437-SVW (C.D. Cal. filed August 24, 2005)(finding that “considerable distance” of 30 miles between Molski’s residence and gas station weighed against Molski establishing a likelihood of future harm); Delil v. El Torito Rest., No. C93-3900, 1997 WL 714866, at *3 (N.D.Cal.1997)(<HOLDING>); Brother v. Tiger Partner, LLC, 331 F.Supp.2d
holding plaintiff failed to demonstrate disparate treatment because she failed to show she was similarly situated to coworker to whom she compared herself holding that a plaintiff failed to establish likelihood of future harm in part because she lived over 100 miles from restaurant holding that icecovered steps did not present a high likelihood of harm or severity of harm holding that likelihood of irreparable harm must be based on evidence in the record not unsupported and conclusory statements regarding harm the plaintiff might suffer holding that plaintiffs who alleged a subjective chill of their first amendment rights failed to establish specific present objective harm or a threat of specific future harm