Love v. Skillman

Background

Samuel Love alleges that Gary Skillman, doing business as The Northern Inn Motel, violated the Americans with Disabilities Act (ADA), 42 U.S.C. § 12101 et seq., and California’s Unruh Civil Rights Act. The complaint challenges the motel’s reservation system.

Legal issue identified by the court

The court described the dispute as involving the scope of the ADA regulations governing reservations systems for lodging facilities. The regulations require a covered lodging facility to allow people with disabilities to make reservations for accessible rooms during the same hours and in the same manner as people who do not need accessible rooms. They also require the facility to describe accessible features in enough detail to allow people with disabilities to independently assess whether a hotel or room meets their accessibility needs. The court referred to these requirements collectively as the “Reservations Rule.” Love alleges that Skillman’s reservation system violated that rule by failing to describe the motel’s accessibility features in sufficient detail.

Procedural history and ruling

The court noted that similar cases in federal district courts in California had produced different outcomes at the pleading stage. It also noted that the Ninth Circuit had not yet interpreted the Reservations Rule and that appeals were pending in two related cases addressing the issues raised by Love’s complaint.

The court issued an order to show cause, meaning it required the parties to explain why the case should not be stayed, or paused, pending a Ninth Circuit ruling in one or both of those appeals. The court ordered both parties to submit three-page written responses by September 10, 2021. The order did not resolve whether Love’s ADA or Unruh Act claims were legally sufficient and did not decide the merits of those claims.