Langer v. Music City Hotel LP

Background

Chris Langer alleged that Music City Hotel LP and Pacific Equities West, LLC, which together own and operate the Music City Hotel, violated the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act. Langer identifies as a person with physical disabilities, uses a wheelchair for mobility, and has permanent partial hearing loss. He alleged that, when he visited the hotel’s website on February 6, 2020, its accessibility information was not detailed enough to let him independently determine whether a room would meet his needs.

The operative complaint asserted one ADA claim and one Unruh Act claim. Langer sought injunctive relief under the ADA and an unspecified amount of statutory damages. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim.

Judicial notice

The court granted the request for judicial notice of the current contents of the defendants’ website for the limited purpose of recognizing what the website currently said. It also took judicial notice of a parcel record from the San Francisco Planning Department showing that the hotel building was constructed in 1907. The court denied as moot the request to take judicial notice of a 2010 consent order because it did not consider that exhibit in deciding the motion.

ADA claim

The court considered whether the hotel’s current website complied with the ADA’s Reservations Rule, which requires hotels to describe accessible features in enough detail to allow people with disabilities to independently assess whether a room meets their needs. The website stated that the historic building was not accessible to people requiring wheelchair access, that guest rooms required climbing two flights of stairs, that there was no elevator, and that most rooms had shared bathrooms. It also described limited grab-bar availability and invited people with accessibility questions to contact the hotel.

The court held that, because the hotel was built in 1907 and had limited accessibility features, the website met the minimum requirements that apply to older hotels. The court rejected Langer’s argument that the ADA required more detailed descriptions, including additional information concerning auditory accessibility. It concluded that the website satisfied the Reservations Rule.

The court separately ruled that the ADA claim was moot. It found that the defendants had apparently changed the website after the case began, that the changes removed the alleged barriers, and that Langer had not shown that the alleged violation was reasonably likely to recur. Because private plaintiffs may obtain only injunctive relief under the ADA, the court concluded that no effective injunctive relief remained available.

Unruh Act claim

The court found that the Unruh Act claim remained live because it sought damages for past harm. However, that state-law claim was before the federal court only through supplemental jurisdiction, which allows a federal court to hear related state-law claims in some circumstances. After dismissing the federal ADA claim, the court declined to exercise supplemental jurisdiction over the Unruh Act claim. It stated that it had not considered the merits of that claim and that Langer had not shown significant inconvenience from refiling in state court.

Disposition

The court dismissed the ADA claim as moot and dismissed the state-law claims without prejudice for refiling in state court. The order was signed by United States District Judge Phyllis J. Hamilton.