Love v. Handlery Hotels, Inc.

Background

Samuel Love alleged that Handlery Hotels, Inc.’s reservation website did not describe accessible features in enough detail to allow him, as a wheelchair user, to determine independently whether an accessible hotel room would meet his needs. He alleged that the lack of information deterred him from booking a room. He asserted a claim under Title III of the Americans with Disabilities Act (ADA) and a related claim under California’s Unruh Civil Rights Act. He sought an injunction, damages under the Unruh Act, attorney’s fees, and costs.

Handlery moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. Handlery argued that the website complied with the ADA and that numerous California federal courts had reached the same conclusion regarding similar information.

Judicial Notice

The court granted Handlery’s request for judicial notice as to exhibits 1 and 2, which consisted of the hotel’s website and pages describing accessible rooms, and exhibit 4, a consent decree from another ADA enforcement case. The court denied the request as to exhibit 3, a list of Love’s other cases, because it was not relevant to the issues before the court.

ADA Claim

The ADA’s Title III regulations require a lodging business to identify and describe accessible hotel and guest-room features in enough detail to reasonably allow people with disabilities to assess whether a room meets their accessibility needs. Love argued that the website should provide additional details, including door clearances, space beside the bed, desk clearance, toilet-transfer information, sink and mirror features, and shower equipment.

The court found that the regulation’s phrases “enough detail” and “reasonably permit” were ambiguous. It therefore gave substantial weight to guidance from the U.S. Department of Justice. That guidance explains that a reservation system is not intended to be an accessibility survey, but requires specific accessibility information. It also recognizes that guests may contact the hotel for more detailed information about matters such as room and bathroom layout, shower design, grab-bar locations, and other amenities.

The court concluded that Handlery’s website provided extensive accessibility information, including wheelchair-accessible switches and outlets, lever door hardware, lowered peepholes and closet rods, accessible toilets and sinks, bathroom-door clearance, safety bars, lowered towel bars, roll-in showers with folding seats in some rooms, and shower-spray extensions in some rooms. The website also listed accessible room types, described features available in each room, and provided telephone and email contact information for additional questions.

The court held that these disclosures exceeded the level of detail contemplated by the Department of Justice’s guidance. It rejected Love’s argument that the website had to list every feature he considered important, explaining that different guests may need different information. The court also relied on the guidance’s recognition that some detailed information may be provided through direct contact with the hotel rather than on the reservation website.

The court found that the website complied with the applicable regulations and that Love therefore failed to state an ADA claim for which relief could be granted. Because the court determined that additional facts could not cure the pleading, it dismissed the first cause of action without leave to amend.

State-Law Claims and Disposition

The court held that the ADA claim supplied the only basis for its original federal jurisdiction. After dismissing that claim, it declined under 28 U.S.C. § 1367(c)(3) to exercise supplemental jurisdiction over Love’s remaining state-law claims.

Judge Thomas S. Hixson granted Handlery’s motion to dismiss. The dismissal was without leave to amend. The opinion does not state a separate disposition using a dismissal-with-prejudice or dismissal-without-prejudice label for the remaining state-law claims; it states that the court declined supplemental jurisdiction over them.