Love v. M W G J LLC

Background

Samuel Love alleged that he is paraplegic and uses a wheelchair for mobility. He brought claims under the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act against M W G J LLC, which owns and operates the Candlelight Inn Napa Valley in Napa, California. Love described himself as an “ADA tester” and alleged that the hotel’s website did not adequately describe the accessibility features of an advertised accessible room.

The complaint specifically identified alleged omissions concerning grab bars near the toilet, wheelchair clearance and hot-water-pipe insulation under the sink, and a doorway at least 32 inches wide. M W G J argued that the website complied with the ADA’s hotel-reservation requirements and moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim.

Court’s Analysis

The court relied on the ADA regulation known as the Reservations Rule, which requires lodging businesses to describe accessible features in enough detail for people with disabilities to assess whether a room meets their needs. The court also relied on guidance from the U.S. Department of Justice stating that a reservation system is not intended to be an accessibility survey.

According to that guidance, a hotel may generally provide information such as the room type, bed size and number, accessible bathing facility, and communication features. More detailed information—including the room and bathroom layout, shower design, and grab-bar locations—may be provided by trained staff after a reservation is made. The court noted that Love did not allege other possible deficiencies, such as failure to provide information required for older hotels, omission of communication features, or an inability of hotel staff to answer questions about room accessibility.

The court concluded that Love’s allegations concerned details that the governing federal standards did not require the website to provide. It therefore found that the complaint did not plausibly allege an ADA violation. The Unruh Act claim also failed because it was based on the same ADA allegations.

Disposition

The court ruled that the complaint should be dismissed but did not determine that amendment would necessarily be futile. Love was permitted to file an amended complaint consistent with the order by November 12, 2021. The court stated that failure to meet that deadline would result in dismissal with prejudice under Federal Rule of Civil Procedure 41(b).

The court denied the requests for judicial notice and to consider information outside the complaint, explaining that a Rule 12(b)(6) motion is ordinarily decided from the complaint itself. Judge James Donato issued the order on October 26, 2021.