Rios v. Leadwell Global Property LLC

Background

Mary Rios alleged that she is an individual with physical disabilities, uses a wheelchair for mobility, and requires an accessible hotel room. She considered staying at the Mark Hopkins San Francisco Hotel, which Leadwell Global Property LLC owns, for a planned October 2020 trip. Rios alleged that, when she visited the hotel’s website, the site did not describe the hotel’s accessibility features in enough detail to let her independently determine whether a particular room met her needs.

Rios asserted one claim under Title III of the Americans with Disabilities Act (ADA) and one claim under California’s Unruh Civil Rights Act. She sought injunctive relief, equitable nominal damages, statutory damages, and attorney’s fees and costs. Leadwell moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim.

Requests for Judicial Notice

Leadwell asked the court to take judicial notice of the hotel’s website materials, court documents from other cases, and a list of lawsuits Rios filed in the Northern District of California. Judicial notice allows a court to accept certain facts or public records without requiring formal proof when they are not reasonably disputable.

The court granted judicial notice of the website materials because Rios’s complaint relied on the website, and neither the authenticity nor relevance of those materials was disputed. The court also granted judicial notice of the submitted court orders and other court documents because they were public records. The court did not find Leadwell’s list of Rios’s lawsuits to be a proper subject of judicial notice, although it stated that courts may rely on other judges’ opinions and orders to the extent they are persuasive.

ADA Claim

Title III of the ADA prohibits discrimination against people with disabilities in public accommodations. The court explained that the ADA’s “Reservations Rule,” 28 C.F.R. § 36.302(e), requires a hotel to identify and describe accessible features in its reservation system in enough detail to reasonably permit people with disabilities to independently assess whether a hotel or room meets their accessibility needs.

Leadwell argued that its website complied with the Reservations Rule because it identified accessible features in the hotel’s guest rooms and public areas and described accessibility features for a particular room type, including accessible tubs or an accessible roll-in shower. Leadwell also argued that the rule did not require the website to provide every potentially relevant accessibility detail.

Rios argued that the website needed to provide more information, including specific measurements for bed clearance, desk height, and roll-in showers. The court concluded that the website’s descriptions—such as “ADA Rooms & Routes,” “Wheelchair Accessible Closets,” and “Padded Plumbing/Clearance Beneath Vanity”—provided notice that the hotel had accessible rooms. The court also concluded that the term “accessible” was not merely a conclusion because the term is defined in the ADA Accessibility Guidelines to convey compliance with ADA standards.

The court found that the Department of Justice guidance did not require hotels to conduct an accessibility survey or list every possible detail on their websites. Because Rios identified no authority requiring the specific measurements she sought, and because similar website information had been found sufficient in other cases, the court concluded that Leadwell’s website complied with the Reservations Rule. It dismissed Rios’s ADA claim.

Unruh Act Claim

Rios’s Unruh Act claim was based on the alleged ADA violation. The court held that, because the ADA claim failed, the dependent Unruh Act claim also failed, and it dismissed that claim.

Disposition

The court granted Leadwell’s motion to dismiss. It dismissed both the ADA and Unruh Act claims without leave to amend because it determined that amendment would be futile. The court also vacated the hearing that had been scheduled for June 3, 2021.