Love v. FYI MC, LLC

Background

Samuel Love alleged that he uses a wheelchair and visited the hotel’s website to book an accessible room for a planned trip. He claimed the website did not provide enough detail about features such as door widths, bed clearance, bathroom fixtures, grab bars, sinks, mirrors, and showers. He asserted claims under Title III of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act.

The defendants identified in the motion were FYI MC, LLC and PYP GE LLC. They moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not adequately state a legal claim. The defendants also asked the court to take judicial notice—meaning to consider without treating the material as ordinary evidence—of screenshots from the hotel’s website. The court granted that request because the complaint referred to the website and Love did not oppose the request.

ADA claim

Love based his ADA claim on the federal “Reservations Rule,” which requires hotels to identify and describe accessible features in hotels and guest rooms offered through reservation services in enough detail to reasonably allow people with disabilities to assess whether the hotel or room meets their needs.

The court relied on guidance from the Department of Justice distinguishing hotels built to comply with the 1991 accessibility standards from older hotels with limited accessibility. The hotel was built before 1991 and, according to the supplemental briefing, was not compliant with those standards. The court therefore applied the guidance for older properties.

The court concluded that the website provided sufficient information. The website stated that several areas were not accessible to people requiring mobility assistance, that the property was not currently accessible to people requiring wheelchair access, and that the path of travel to the guestroom might not be accessible. It also identified an accessible parking space, an accessible side-approach registration desk, certain room features, a 36-inch entrance-door width, and the hotel’s plan to build a fully accessible guestroom. The court held that this information reasonably allowed Love to determine whether the hotel and its rooms met his accessibility needs and granted the defendants’ motion to dismiss the ADA claim.

The court distinguished a decision in which a hotel website did not identify important inaccessible features, doorway widths, or the accessible route to the rooms. The court stated that this hotel’s website provided more detailed information and also supplied a telephone number for additional questions.

Unruh Act claim

Love’s Unruh Act claim was based on his ADA claim. The court stated that because Love had not adequately alleged an ADA violation, he necessarily had not adequately alleged an Unruh Act violation. The opinion’s conclusion states that the defendants’ motion to dismiss was granted with prejudice in its entirety.

Disposition and discrepancy

The order states that it takes judicial notice of the website screenshots, grants with prejudice “Ashford’s motion to dismiss in its entirety,” directs the clerk to enter judgment and close the file, and disposes of Docket No. 9. Earlier portions of the opinion identify the moving defendants as FYI MC, LLC and PYP GE LLC, and identify Docket No. 13 as the motion to dismiss. The opinion does not explain the references to “Ashford” or Docket No. 9 in the conclusion.