Acheson Hotels, LLC v. Laufer

2023-12-05
Share:

Headline: Court dismisses hotel accessibility lawsuit as moot, vacating the appeals-court ruling and leaving unresolved whether website ‘testers’ can sue under the ADA, affecting hotels and disability testers nationwide.

Holding: This case is vacated as moot; the Court declined to decide whether website 'testers' have a right to sue under the ADA and remanded with instructions to dismiss.

Real World Impact:
  • Leaves unresolved whether website 'testers' can sue under the ADA.
  • Vacates the First Circuit ruling and sends the case back as moot.
  • Hotels and testers face different rules across federal circuits while the split remains.
Topics: disability access, hotel websites, private enforcement, standing to sue, Americans with Disabilities Act

Summary

Background

Deborah Laufer is a wheelchair user who searches hotel websites for missing accessibility information and has filed hundreds of lawsuits under the Americans with Disabilities Act to force compliance. Acheson Hotels was sued because its site did not state whether accessible rooms were available. Federal appeals courts are divided on whether people who do this kind of website testing have a legal right to sue, and the Supreme Court agreed to resolve that split. After one of Laufer’s lawyers faced sanctions, Laufer voluntarily dismissed her suits and told the Court the case was moot.

Reasoning

The Court said it has discretion to decide jurisdictional questions in any order but chose to resolve mootness first because Laufer had dismissed the case. The majority concluded the dispute was no longer live, vacated the First Circuit’s favorable judgment, and remanded with instructions to dismiss the case as moot. The Court acknowledged concerns that parties might try to manipulate its docket, but it was not convinced Laufer abandoned the case to avoid review.

Real world impact

Because the Court dismissed the case as moot, it did not resolve whether people who search hotel booking sites to test ADA compliance have a right to sue. The split among the federal appeals courts therefore remains, leaving hotels and testers subject to different rules by circuit. This decision is not a final merits ruling and the legal question could return to the Court in a future case.

Dissents or concurrances

Justice Thomas would have reached the standing question and concluded Laufer lacked a right to sue, saying testers enforce public obligations rather than remedy personal harms. Justice Jackson agreed the case is moot but warned that vacating lower-court judgments should be used carefully and considered separately.

Ask about this case

Ask questions about the entire case, including all opinions (majority, concurrences, dissents).

What was the Court's main decision and reasoning?

How did the dissenting opinions differ from the majority?

What are the practical implications of this ruling?

Related Cases