Strojnik v. GF Carneros Tenant, LLC

Background

Peter Strojnik sued GF Carneros Tenant, LLC, doing business as Carneros Resort and Spa. He sought injunctive relief and monetary damages. The complaint asserted four claims: violation of the Americans with Disabilities Act (ADA), violation of California’s Unruh Act, violation of the California Disabled Persons Act, and negligence.

Strojnik alleged that he is disabled because of several medical conditions, including right-sided neural foraminal stenosis with symptoms of femoral neuropathy, prostate cancer, renal cancer, and a degenerative right knee. He alleged that he planned to visit California Wine Country and reviewed hotel-booking websites. According to the complaint, third-party booking websites and the resort’s own website did not adequately identify or describe mobility-related accessibility features and accessible guest rooms. He also alleged that accessible-room reservations were not made available in the same way as other reservations.

Strojnik alleged that online information and photographs showed barriers to access at the resort. Because of the alleged violations, he chose to book a room at a different hotel. He further alleged that he intended to visit the resort when the alleged accessibility problems were corrected.

Motion and legal standard

The resort moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which permits dismissal when the court lacks subject-matter jurisdiction. The resort argued that Strojnik lacked standing, a requirement that a plaintiff show an actual or imminent injury, a connection between the injury and the defendant’s conduct, and a likelihood that a favorable decision would remedy the injury.

The court treated the motion as a facial challenge to standing. In that type of challenge, the court accepts the complaint’s factual allegations as true and draws reasonable inferences in the plaintiff’s favor. The court distinguished a factual challenge, in which the defendant contests the truth of the allegations and the court need not accept them as true.

Court’s analysis

The court relied on Ninth Circuit precedent involving alleged ADA access barriers at hotels. That precedent held that plaintiffs sufficiently allege an injury when they claim that they intend to visit hotels, were deterred by alleged ADA violations, and will visit when the violations are corrected.

The court found that Strojnik made similar allegations. He alleged that he intended to visit the resort but was deterred by what he claimed were ADA violations, and that he would visit after the alleged noncompliance was cured. The court therefore held that he had alleged standing sufficient to withstand the resort’s facial challenge.

The resort also argued that Strojnik could not show an injury because he had not demonstrated a genuine intent to return and had not encountered or been made aware of ADA violations. The court rejected those arguments at this stage because they would require the court to disregard or construe against the complaint’s allegations. Strojnik specifically alleged that the reservation systems failed to identify the resort’s accessibility and that he observed or identified other access barriers.

Disposition

Judge Jacquelyn Scott Corley denied Carneros Resort’s motion to dismiss. The order addressed whether Strojnik sufficiently pleaded standing; it did not decide whether the resort violated the ADA, the California statutes, or negligence law. The order disposed of Docket No. 20.