Whitaker v. Casa Madrona Hotel and Spa, LLC
- Edward Chen
- 3:21-cv-00629
- U.S. District Court · Northern District of California
- 3
In Whitaker v. Casa Madrona Hotel, Judge Chen denied the Hotel’s motion to dismiss claims about disability-access information.
Brian Whitaker’s ADA and California Unruh Civil Rights Act lawsuit against Casa Madrona Hotel and Spa, LLC was allowed to proceed past the motion-to-dismiss stage; the court did not make a final finding that the Hotel violated the ADA regulation.
What happened
In Whitaker v. Casa Madrona Hotel and Spa, LLC, Brian Whitaker sued the Hotel under the federal Americans with Disabilities Act and California’s Unruh Civil Rights Act.
The dispute concerns a federal rule requiring hotels to describe accessible features in enough detail for people with disabilities to independently assess whether a hotel or room meets their needs. Whitaker alleged that the Hotel’s website made this information difficult to find, incomplete, or too general.
The court denied the Hotel’s motion to dismiss. Judge Edward M. Chen ruled that Whitaker’s allegations plausibly suggested that he could be entitled to relief, but did not decide that the Hotel had violated the rule as a matter of law.
The detailed version
- Whitaker v. Casa Madrona Hotel and Spa, LLC · No. 3:21-cv-00629
- Edward Chen
- Apr. 26, 2021
Background
Brian Whitaker sued Casa Madrona Hotel and Spa, LLC, alleging violations of the federal Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. The main issue addressed in the order was 28 C.F.R. § 36.302(e)(1)(ii), a regulation requiring a place of lodging to identify and describe accessible features in its hotels and guest rooms in enough detail to reasonably allow people with disabilities to independently assess whether a particular hotel or room meets their accessibility needs.
Whitaker challenged information on the Hotel’s website. The court noted allegations that some accessibility information was difficult to locate, including information provided only after a user took steps toward booking a room and a link that was not conspicuous. The court also noted allegations that some information was conclusory, such as stating only “ADA Accessible,” and that descriptions on other pages, including pages describing ADA guest rooms, were sparse, such as references to a bathtub and grab bars.
Legal standard and analysis
At the motion-to-dismiss stage, the plaintiff needed only to plausibly suggest an entitlement to relief. The court concluded that a reasonable jury could find in Whitaker’s favor based on the alleged location, organization, and level of detail of the Hotel’s accessibility information.
The court did not decide that the Hotel had violated the ADA regulation as a matter of law. It recognized that the Hotel had a fair argument that a reasonable jury could find in its favor based on website evidence concerning renovations in 2003 and 2014, general statements about ADA accessibility, photographs, and a statement that ADA guest rooms could be booked online subject to availability, with a telephone number and email address for additional questions or booking assistance.
Ruling
Judge Edward M. Chen denied the Hotel’s motion to dismiss and stated that the order disposed of Docket No. 9. The order allowed the case to proceed past this motion but did not resolve whether the Hotel ultimately violated the ADA regulation.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.