Acheson Hotels, LLC v. Laufer

Background

A woman who uses a wheelchair, Deborah Laufer, searched hotel websites for required accessibility information and sued when sites did not state whether accessible rooms existed. She brought hundreds of suits claiming hotels violated the ADA reservation rule. Hotels defended by saying Laufer lacked a personal injury because she never intended to stay. After this Court agreed to decide the issue, Laufer dismissed her cases following sanctions against her lawyer and filed a suggestion that the case was moot.

Reasoning

The core question was whether someone who hunts for ADA website violations but has no plan to stay has the right to sue in federal court. The Court concluded Laufer’s suit was moot and vacated the First Circuit’s favorable judgment under the Munsingwear practice, instructing the court below to dismiss. The Court declined to resolve the standing question, though it noted the active split among federal appeals courts about similar tester suits.

Real world impact

Because the Court dismissed the case as moot, it did not settle the national question about when accessibility “testers” may sue. Hotels and disability advocates will continue to face different rules in different circuits until the Court or Congress acts. This ruling is not a final decision on the merits and could be revisited in a future case that squarely presents standing.

Dissents or concurrances

Two Justices wrote separately: Justice Thomas would have reached the standing question and concluded Laufer lacks standing, while Justice Jackson agreed the case is moot but urged stricter limits on automatically vacating lower-court judgments.