Arroyo v. Huskies Owner LLC

Background

Rafael Arroyo alleged that Huskies Owner LLC operates the Kimpton Sir Francis Drake Hotel and its reservation website. Arroyo, who uses a wheelchair, alleged that the website did not reasonably identify and describe accessible features in the hotel’s guest rooms. He specifically alleged that the website did not provide information about the accessibility of toilets and sinks or the clear space next to beds. He alleged that this prevented him from independently determining whether a room met his accessibility needs and barred him from booking a room.

Arroyo asserted claims under Title III of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. He sought injunctive relief and attorney’s fees under both laws and damages under the Unruh Act. Huskies Owner LLC moved to dismiss under Rule 12(b)(6), which allows dismissal when a complaint does not state a claim on which relief can be granted. The defendant argued that its website complied with the ADA’s hotel-reservation rule and that the Unruh Act claim depended on the ADA claim. It also argued that the ADA claim was barred by a prior ruling, but the court did not reach that argument.

ADA Claim

The ADA’s reservation rule requires places of lodging to identify and describe accessible hotel and guest-room features in enough detail to reasonably allow people with disabilities to assess independently whether a room meets their needs. The court explained that the rule does not require a reservation system to function as an accessibility survey. It relied on Department of Justice guidance stating that, for hotels built in compliance with applicable accessibility standards, potentially sufficient information may include the general room type, bed size and number, type of accessible bathing facility, and available communication features.

The court held that the information on Huskies Owner LLC’s website was sufficient as a matter of law. The website identified accessible rooms and common spaces, described room types and bed configurations, listed roll-in showers or accessible bathtubs with grab bars, and identified communication features such as bed shakers, closed-captioning or decoder devices, telephone amplifiers, and teletypewriter capabilities. The court also considered the website’s provision of a telephone number for guests seeking information about more specific needs.

The court acknowledged tension in the Department of Justice guidance, including its statement that the Department could not specify the required information in every situation and its use of the word “may” when describing potentially sufficient information. Nevertheless, the court followed what it described as the majority view among recent district court decisions in the circuit. It concluded that requiring the additional information Arroyo sought would conflict with the guidance’s statement that a reservation system is not intended to be an accessibility survey.

The court further noted that Arroyo did not allege that any physical feature of the hotel violated applicable ADA building standards. It held that the website’s disclosures, together with a telephone number for questions about more specific needs, satisfied the reservation rule. The court therefore held that Arroyo failed to state an ADA claim and found that amendment would be futile. Defendant’s motion to dismiss the ADA claim was GRANTED, and the claim was DISMISSED with prejudice.

Unruh Act Claim and Disposition

The only jurisdictional basis Arroyo identified for his Unruh Act claim was supplemental jurisdiction, meaning the federal court’s authority to hear a related state-law claim alongside a federal claim. After dismissing the ADA claim, the court declined to exercise supplemental jurisdiction over the Unruh Act claim. The court stated that, in the usual situation where all federal claims are eliminated before trial, the relevant considerations generally favor declining jurisdiction over the remaining state-law claims.

The court’s final order stated that Defendant’s Motion was GRANTED, Arroyo’s ADA claim was DISMISSED with prejudice, and Defendant’s Unruh Act claim was DISMISSED for lack of jurisdiction. The Clerk was directed to enter judgment in favor of Defendant and close the case. Judge Joseph C. Spero signed the order as Chief Magistrate Judge.