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N.D. Cal.Procedural orderFiled Nov. 1, 2021

Arroyo v. Harbor View Hotels Inc.

Judge
Vince Chhabria
Docket
3:21-cv-01080
Court
U.S. District Court · Northern District of California
Pages
2
ADA / DisabilityMotion to DismissCivil Procedure
In one sentence

In Arroyo v. Harbor View Hotels Inc., Judge Chhabria granted the hotel's motion to dismiss Rafael Arroyo's accessibility-information claim, allowing amendment.

Who this affects

Rafael Arroyo and Harbor View Hotels Inc. The order allowed Arroyo 14 days to file an amended complaint and stated that the dismissal would be with prejudice if he did not do so.

What happened

In Arroyo v. Harbor View Hotels Inc., Rafael Arroyo challenged the information provided on Harbor View Hotels Inc.'s reservation website about accessible rooms.

The court found that the website's descriptions satisfied the relevant accessibility regulation and granted the hotel's motion to dismiss. Arroyo may file an amended complaint within 14 days if he can identify something unusual about the rooms requiring more information.

Judge Vince Chhabria allowed the amendment, but stated that the dismissal will be with prejudice if Arroyo does not file an amended complaint within that period.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Arroyo v. Harbor View Hotels Inc. · No. 3:21-cv-01080
Judge
Vince Chhabria
Date
Nov. 1, 2021

Background

Rafael Arroyo's case concerned whether Harbor View Hotels Inc.'s hotel reservation website provided enough information about accessible hotel rooms and features. The relevant regulation requires reservation systems to describe accessible features in enough detail for people with disabilities to independently assess whether a hotel or room meets their needs.

Court's Analysis

The court explained that reservation systems following Department of Justice guidance generally satisfy the regulation. Harbor View's website stated that the hotel was accessible and, for each accessible room, described the room type, bed size and number, accessible bathing facility, and available communication features. The court concluded that this information satisfied the guidance.

The court also recognized that basic information might be insufficient if something unusual about a particular room could create problems for a disabled person. It therefore allowed Arroyo to amend if he could allege that something specific about the rooms made additional information necessary.

Ruling

The court granted Harbor View Hotels Inc.'s motion to dismiss with leave to amend. Any amended complaint had to be filed within 14 days. The court stated that if Arroyo declined to amend, the dismissal would be with prejudice, meaning the case could not be refiled. Judge Vince Chhabria signed the order.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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