Arroyo v. Pollock 1400 ECR Owner, LLC

Background

Rafael Arroyo alleged that he is paraplegic and uses a wheelchair. He planned to travel to Menlo Park, California, and visited the Park James Hotel’s website reservation system on December 20, 2020, to book an accessible room. He alleged that the website did not provide enough information about accessible rooms for him to determine independently whether a room would meet his accessibility needs.

Pollock 1400 ECR Owner, LLC owned the hotel when Arroyo visited the website. The hotel was later foreclosed upon and sold to PJ Hotel, LLC on February 4, 2021. PJ was the hotel’s current owner when Arroyo filed his amended complaint. Arroyo sought ADA injunctive relief against PJ and damages under the Unruh Civil Rights Act against Pollock. He voluntarily dismissed his ADA claim against Pollock and stated that he was not seeking Unruh Act liability against PJ.

PJ’s Motion to Dismiss

PJ argued that Arroyo lacked standing to bring the ADA claim because PJ did not own or operate the hotel when Arroyo visited the website. Article III standing requires a plaintiff to show an actual injury, a connection between that injury and the defendant’s conduct, and a likelihood that a favorable decision would remedy the injury.

The court concluded that Arroyo’s alleged injury could not have been caused by PJ because PJ did not become the hotel’s owner until after the December 2020 website visit. The court therefore held that Arroyo had not established standing to sue PJ and that the federal court lacked jurisdiction over the ADA claim. It granted PJ’s motion to dismiss the ADA claim for lack of jurisdiction.

Pollock’s Motion and the Unruh Act Claim

Pollock moved to dismiss the remaining Unruh Act claim on the merits, arguing that the alleged website deficiencies did not violate the statute. The court expressly declined to decide that issue.

After dismissing the federal ADA claim, the court concluded that supplemental jurisdiction—the federal court’s discretionary authority to hear related state-law claims—was the only basis for jurisdiction over the Unruh Act claim. The court declined to exercise supplemental jurisdiction and dismissed the Unruh Act claim against Pollock without prejudice.

Disposition

The court granted PJ’s motion to dismiss the ADA claim for lack of jurisdiction, declined to exercise supplemental jurisdiction over the remaining Unruh Act claim against Pollock, dismissed that claim without prejudice, and directed the Clerk to close the file. Judge Jacqueline Scott Corley stated that the order disposed of Docket Nos. 20 and 31.