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Acheson Hotels, LLC v. Laufer

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Supreme Court of the United States
Acheson Hotels, LLC v. Laufer
Term: 2023
Important Dates
Argued: October 4, 2023
Decided: December 5, 2023
Outcome
Vacated and remanded
Vote
9-0
Majority
Amy Coney Barrett • Chief Justice John Roberts • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh
Concurring
Clarence Thomas • Ketanji Brown Jackson

Acheson Hotels, LLC v. Laufer is a case that was decided by the Supreme Court of the United States on December 5, 2023, during the court's October 2023-2024 term. The case argued before the Supreme Court of the United States on October 4, 2023.

The court vacated the decision of the United States Court of Appeals for the First Circuit in a 9-0 ruling, holding that the case is moot. Justice Amy Coney Barrett delivered the majority opinion of the court. Justice Clarence Thomas filed a concurring opinion. Justice Ketanji Brown Jackson also filed a concurring opinion.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the Americans with Disabilities Act. Click here to learn more about the case's background.
  • The questions presented: "Does a self-appointed Americans with Disabilities Act "tester" have Article III standing to challenge a place of public accommodation's failure to provide disability accessibility information on its website, even if she lacks any intention of visiting that place of public accommodation?"[2]
  • The outcome: The court vacated the case as moot and remanded it to the United States Court of Appeals for the First Circuit to be dismissed.


    • The case came on a writ of certiorari to the United States Court of Appeals for the First Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • December 5, 2023: The court vacated the decision of the United States Court of Appeals for the First Circuit in a 9-0 ruling.
    • October 4, 2023: The U.S. Supreme Court heard oral argument.
    • March 27, 2023: The U.S. Supreme Court agreed to hear the case.
    • November 4 2022: Acheson Hotels, LLC appealed to the U.S. Supreme Court.
    • October 5, 2022: The United States Court of Appeals for the First Circuit reversed the United States District Court for the District of Maine's ruling and held that Laufer had standing to pursue injunctive relief.

    Background

    Acheson Hotels, LLC v. Laufer is a case involving the Americans with Disabilities Act (ADA). The Court was asked to determine whether someone has standing if they do not intend to visit the hotel they are suing.[1][3][4]

    Under the ADA, hotel reservation portals must provide accessibility information about their accommodations for individuals with disabilities.[1]

    Deborah Laufer, the respondent, is disabled. On her own accord and with no intention to visit, she reviewed Acheson Hotels’ website. Laufer sued the hotel, alleging that their website did not provide sufficient information to determine whether her disabilities could be accommodated at the hotel. In an effort to advocate for individuals with disabilities, Laufer has brought over 600 lawsuits against hotels, including Acheson Hotels, under the ADA.[1][3][4]

    The United States Court of Appeals for the First Circuit held that Laufer had standing to sue in federal court and had standing to pursue injunctive relief.[1]

    Acheson Hotels asked the U.S. Supreme Court to review the First Circuit’s decision. They argued that Laufer does not have standing because she had no intention of visiting the hotel.[3][4]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Does a self-appointed Americans with Disabilities Act "tester" have Article III standing to challenge a place of public accommodation's failure to provide disability accessibility information on its website, even if she lacks any intention of visiting that place of public accommodation?

    [5]

    		”

    Oral argument

    Audio

    Audio of oral argument:[6]




    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 9-0 opinion, the court vacated the judgment of the United States Court of Appeals for the First Circuit, holding that the case is moot. Justice Barrett delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Amy Coney Barrett wrote:[1]

    “

    We are sensitive to Acheson’s concern about litigants manipulating the jurisdiction of this Court. We are not convinced, however, that Laufer abandoned her case in an effort to evade our review. She voluntarily dismissed her pending ADA cases after a lower court sanctioned her lawyer. She represented to this Court that she will not file any others. Laufer’s case against Acheson is moot, and we dismiss it on that ground. We emphasize, however, that we might exercise our discretion differently in a future case. [5]

    		”
    —Justice Amy Coney Barrett

    Thomas' concurring opinion

    Justice Clarence Thomas filed a concurring opinion.

    In his concurring opinion, Justice Thomas wrote:[1]

    “

    At both parties’ request, this Court agreed to answer a question that has divided the Courts of Appeals: whether plaintiffs like Laufer have standing to bring these claims. The Court decides not to decide that question because, after briefing began, Laufer voluntarily dismissed her claim in the District Court. I would answer this important and recurring question, which, as all agree, we have the authority to do. And, I conclude that Laufer lacks standing. [5]

    		”
    —Justice Clarence Thomas

    Jackson's concurring opinion

    Justice Ketanji Brown Jackson filed a concurring opinion.

    In her concurring opinion, Justice Jackson wrote:[1]

    “

    In my view, when mootness ends an appeal, the question of what to do with the lower court’s judgment, if anything, raises a separate issue that must be addressed separately. [5]

    		”
    —Justice Ketanji Brown Jackson

    Text of the opinion

    Read the full opinion here.

    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 SupremeCourt.gov, "ACHESON HOTELS, LLC v. LAUFER ," accessed December 5, 2023 Cite error: Invalid <ref> tag; name "opinion" defined multiple times with different content
    2. ↑ 2.0 2.1 SupremeCourt.gov, "22-429 ACHESON HOTELS, LLC V. LAUFER," accessed March 27, 2023
    3. ↑ 3.0 3.1 3.2 SupremeCourt.gov, "ACHESON HOTELS, LLC, v. DEBORAH LAUFER," November 4, 2022
    4. ↑ 4.0 4.1 4.2 SCOTUSblog, "Court takes up civil rights “tester” case," March 27, 2023
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 4, 2023
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 4, 2023
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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