California’s Disabled Persons Act (Civ. Code 54-55.3) and the state’s Building Standards Code do not require merchants to provide a means of access for disabled persons to their stores that does not involve traveling behind parked cars.  Here, a Ralphs Grocery store did not violate the act by its conventional parking lot design that allowed disabled persons like other patrons to leave their cars and enter the store by traversing the parking lot in the lanes for vehicular travel which required traveling behind parked cars.  Also, since that means of accessing the store was open and obvious, the store was not required to provide signage identifying it as the means for handicap access.

California Court of Appeal, Second District, Division 4 (Manella, J.); July 12, 2018; 2018 Cal. App. LEXIS 624