Love v. CHSP TRS San Francisco LLC

Background

Samuel Love alleged that CHSP TRS San Francisco LLC violated Title III of the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. Love alleged that he is paraplegic and uses a wheelchair. He planned to travel to San Francisco and visited the Le Meridien Hotel’s reservation website to book an accessible room. According to the amended complaint, the website listed various accessible features but did not provide enough specific information about items such as bed clearance, desk and sink dimensions, bathroom features, and shower equipment.

The ADA’s reservation regulation requires lodging facilities to describe accessible features in enough detail to reasonably allow people with disabilities to independently assess whether a hotel or room meets their needs. The court referred to these requirements as the “Reservations Rule.” CHSP TRS moved to dismiss the amended complaint under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to state a legally valid claim. Love opposed the motion.

Court’s Analysis

The court held that the Reservations Rule does not generally require a hotel to confirm on its reservation website that every feature already required by current ADA standards is compliant. The court reasoned that requiring such confirmations would be redundant because an older facility that does not comply with current standards must disclose that noncompliance.

The court also held that reservation websites must provide information about important features that either do not comply with current standards or can be provided in several acceptable ways. For example, a hotel may need to identify whether an accessible bathroom has a bathtub or a roll-in shower. The court rejected both Love’s argument that hotels must confirm compliance for all “core, essential features” and the defendant’s apparent argument that hotels need only list the features specifically mentioned in Department of Justice guidance.

Applying that interpretation, the court found that Love’s allegations did not state a claim. The website already identified 32-inch guest-room doorways, making that issue moot. Bed clearance, sink requirements, toilet features, shower grab bars, and detachable shower wands were treated as features required by the current standards; the court said a compliant hotel need not separately confirm those features. Shower seats were optional under the ADA, and the Reservations Rule did not require the hotel to list optional amenities. Love did not allege that the hotel failed to comply with current standards or identify specific noncompliant features.

Other Request and Disposition

The defendant asked the court to take judicial notice of website printouts, a list of cases Love had filed in California federal courts, hotel building-permit records, and a consent decree involving the Department of Justice and a hotel chain. Because the court did not rely on those materials, it denied the request for judicial notice as moot.

The court granted the defendant’s motion to dismiss. It dismissed the first amended complaint without leave to amend, finding that additional factual detail about the identified features would not cure the deficiencies, and ordered the clerk to close the case.