Arroyo v. Dorcich Farms, LLC
- Lucy Koh
- 5:20-cv-08216
- U.S. District Court · Northern District of California
- 4
In Arroyo v. Dorcich Farms, LLC, Judge Koh dismissed the first amended complaint with prejudice because the hotel website satisfied accessibility requirements.
Rafael Arroyo’s ADA and California Unruh Civil Rights Act claims were dismissed with prejudice; Defendants obtained dismissal of the first amended complaint.
What happened
In Arroyo v. Dorcich Farms, LLC, Rafael Arroyo challenged the accessibility information on Defendants’ hotel website under the Americans with Disabilities Act and California’s Unruh Civil Rights Act. He did not oppose Defendants’ motion to dismiss, even though he was represented by counsel.
The court held that the website described accessible common areas, travel routes, and guest rooms, and explained how visitors could obtain more information. The court concluded that the website met the federal rule requiring hotels to provide enough information for people with disabilities to assess accessibility. Because the state claim depended on a valid federal disability claim, the court also found that it failed.
Judge Lucy Koh granted Defendants’ unopposed motion to dismiss the first amended complaint with prejudice, finding that amendment would be futile. The court denied as moot Defendants’ earlier motion challenging jurisdiction and Arroyo’s request to schedule a settlement meeting.
The detailed version
- Arroyo v. Dorcich Farms, LLC · No. 5:20-cv-08216
- Lucy Koh
- Apr. 12, 2021
Background
Rafael Arroyo brought claims under the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act concerning the accessibility information on Defendants’ hotel website. Defendants moved to dismiss the first amended complaint for failure to state a claim. Arroyo’s response was due February 12, 2021, but he had not filed one by April 12, 2021. The opinion states that Arroyo was represented by counsel from the Center for Disability Access division of Potter Handy, LLP.
Court’s analysis
The court considered Defendants’ motion unopposed and addressed its merits. The ADA’s Reservations Rule requires a hotel to identify and describe accessible features well enough to reasonably allow people with disabilities to assess whether the hotel or a guest room meets their accessibility needs. The court found that Defendants’ website described the accessibility of common areas, accessible routes throughout the hotel, and accessible guest rooms. It also told potential guests that they could call for more information about physical features and disability-related services. The court therefore concluded that the website complied with the Reservations Rule and that Arroyo’s ADA claim failed.
The court also held that Arroyo’s Unruh Civil Rights Act claim depended on the allegedly invalid ADA claim. Because the court found no ADA violation, it concluded that the related Unruh claim failed as a matter of law. The court cited other decisions involving similar hotel-website claims and found substantial authority against Arroyo’s claims.
Disposition
Judge Lucy Koh granted Defendants’ unopposed motion to dismiss the first amended complaint with prejudice. The court held that Arroyo failed to state claims under the ADA or the Unruh Civil Rights Act and found that amendment would be futile. The court also granted Defendants’ unopposed request for judicial notice of specified website pages, a list of cases, and a consent decree. Separately, the court denied as moot Defendants’ motion to dismiss the initial complaint for lack of jurisdiction and Arroyo’s motion for administrative relief concerning a settlement meeting.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.