Arroyo v. IA Lodging Santa Clara, L.L.C.

Background

Rafael Arroyo alleged that he is a California resident, is paraplegic, and uses a wheelchair. He sued IA Lodging Santa Clara, LLC, alleging violations of Title III of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. The claims concerned the Hyatt Regency Santa Clara’s reservation website, which the opinion states was owned and operated by IA Lodging Santa Clara, LLC.

Arroyo alleged that the website identified accessible common areas, parking, routes, and several guest-room features, but did not provide specific information such as door clearance, space beside the bed, toilet height and grab bars, sink dimensions, or shower features. He alleged that this lack of information made it difficult and uncomfortable for him to evaluate whether a room met his needs and deterred him from booking.

Arguments and ruling

The defendant raised four arguments: Arroyo filed his First Amended Complaint one day late; he failed to state claims under the ADA and Unruh Act; he lacked Article III standing; and the court should decline supplemental jurisdiction over the Unruh Act claim.

The court granted the defendant’s request for judicial notice of certain case filings, public webpages, and archived webpages. It then held that Arroyo had until February 9, 2021, to amend his complaint as a matter of course after the defendant filed its earlier motion to dismiss, but he filed the First Amended Complaint on February 10. The court therefore granted the motion to dismiss on that ground.

The court also held that the First Amended Complaint failed to state an ADA claim. The ADA’s Reservations Rule requires hotels to identify and describe accessible features well enough to reasonably allow people with disabilities to assess independently whether a hotel or room meets their needs. Relying on Department of Justice guidance that a reservation system is not intended to be an accessibility survey, the court concluded that the defendant’s website provided sufficient information by identifying accessible hotel areas and describing guest-room features. The court stated that the website therefore reasonably permitted individuals with disabilities to assess the hotel and its rooms.

Because the Unruh Act claim depended on an ADA violation, the court held that the Unruh Act claim also failed. The court did not reach the defendant’s standing or supplemental-jurisdiction arguments because the late filing and failure to state a claim independently supported dismissal.

Disposition

The court concluded that amendment would be futile and granted the defendant’s motion to dismiss the First Amended Complaint with prejudice. The court also denied as moot the defendant’s administrative motion to exempt the case from General Order 56.