Arroyo v. PHI Associates, L.P.
- Kandis Westmore
- 4:21-cv-00784
- U.S. District Court · Northern District of California
- 7
In Arroyo v. PHI Associates, Judge Westmore granted PHI’s motion to dismiss with prejudice and denied Arroyo’s administrative-relief motion as moot.
Rafael Arroyo’s ADA and Unruh Civil Rights Act claims against PHI Associates, L.P. were dismissed with prejudice; his motion for administrative relief was denied as moot.
What happened
In Arroyo v. PHI Associates, L.P., Rafael Arroyo alleged that PHI Associates violated the Americans with Disabilities Act by failing to provide enough accessibility information on the Hotel Drisco reservation website. He also alleged that a website photograph showed an inaccessible shower.
The court concluded that the website provided enough information under the ADA’s hotel-reservation rule, including descriptions of accessible rooms, showers, grab bars, and other features. Because Arroyo did not adequately allege a reservation-rule violation, the court also concluded that he lacked standing to pursue barriers shown only in the photograph.
Judge Westmore granted PHI Associates’ motion to dismiss with prejudice, including the related claim under the Unruh Civil Rights Act. The court denied Arroyo’s motion for administrative relief as moot.
The detailed version
- Arroyo v. PHI Associates, L.P. · No. 4:21-cv-00784
- Kandis Westmore
- July 30, 2021
Background
Rafael Arroyo, who uses a wheelchair, sued PHI Associates, L.P. He alleged that the Hotel Drisco’s reservation website violated the Americans with Disabilities Act (ADA) and its hotel-reservation rule, 28 C.F.R. § 36.302(e)(1), because the website did not provide enough information for him to determine whether a room met his accessibility needs. He also alleged, based on a single website photograph, that a roll-in shower had inaccessible controls, lacked a grab bar, and did not provide the required clearance.
PHI Associates moved to dismiss. Arroyo filed a motion for administrative relief seeking an order requiring PHI Associates to provide three dates for a settlement meeting. The court also considered whether the case should be stayed while similar cases were on appeal and declined to stay it.
Court’s analysis
The court held that the website satisfied the ADA’s reservation rule. The website identified accessible rooms and described features including door width, roll-in showers, shower and tub options, grab bars, lever fixtures, and an accessible vanity. It also stated that the hotel’s amenities and public spaces met ADA requirements. The court concluded that the reservation rule was not intended to require an accessibility survey or the specific additional measurements Arroyo sought.
The court further held that Arroyo lacked standing to pursue the alleged barriers shown in the photograph because he had not adequately alleged that the website violated the reservation rule and therefore had not actually encountered an actionable barrier. The court also noted that the photograph’s source and representativeness were unclear and that the photograph alone did not establish that the hotel lacked other compliant facilities.
The court granted PHI Associates’ request for judicial notice except as to the list of Arroyo’s previously filed cases. It treated the website pages and public court documents as materials suitable for judicial notice.
Disposition
Judge Kandis Westmore granted PHI Associates’ motion to dismiss with prejudice. The dismissal included Arroyo’s claim under the Unruh Civil Rights Act because the court viewed that claim as dependent on the unsuccessful ADA claim. The court denied Arroyo’s motion for administrative relief as moot. The case was decided without a hearing.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.