Facts

Orlando Garcia has physical disabilities and uses a wheelchair for mobility. He planned to travel to the Santa Barbara area and went online to book a room at one of the hotels owed by CWI Santa Barbara Hotel (CWI). CWI's reservation website provided information regarding the accessible features, facilities, and areas of the hotel, as well as whether a guest room type is accessible. It lists accessible features in guestrooms, such as, "roll in showers" and "toilet seat at wheelchair height." Garcia brought an action against CWI alleging CWI violated the American with Disabilities Act (ADA) and the Unruh Civil Rights Act (Unruh Act) when he was unable to make a reservation due to insufficient accessibility information. More specifically, Garcia alleged that the items listed on CWI's reservation website does not provide the necessary information he needed to determine whether an accessible guestroom will work for him. CWI moved to dismiss.

PLAINTIFF'S CONTENTIONS: Plaintiff contended that defendant violated the ADA and Unruh Act when defendant's reservation website provided insufficient information for plaintiff to determine whether an accessible guestroom room will work for him. Plaintiff contended defendant violated the Reservations Rule of the ADA by failing to describe its accessibility information with enough specificity to allow him to make an informed choice about whether the room suited his particular needs. Plaintiff contended that greater detail is required for the toilet set height, grab bars at the toilet, clearance and plumbing wrap under the bathroom sink, mirror height, shower type, height of mounted shower amenities, toe and knee clearance at the bedroom desk, bedside transfer clearance, and door widths for all doors in a given guestroom. Plaintiff contended that merely stating something as "accessible" is conclusory and does not provide enough information for an independent assessment, particularly in seeking out specific information that is important to him.

DEFENDANT'S CONTENTIONS: Defendant denied all of the contentions. Defendant contended that plaintiff's complaint failed to state a claim. Defendant contended that its website complied with the ADA, as interpreted by the Department of Justice's (DOJ) 2010 Guidance. Defendant contended that the DOJ 2010 Guidance was not intended to be an accessibility survey and simply required to hotels to provide basic facts about each accessible room, which defendant did. Defendant contended plaintiff did not allege a plausible entitlement to relief because the website listed the hotel's accessibility features and types of available accessible hotel rooms, thus, it complied with the ADA. Defendant also contended that describing something as "accessible" is sufficient to satisfy the ADA because by definition "accessible" meant that the room complied with the ADA. Defendant contended that because the ADA claims should be dismissed, then the Unruh Act claim should be dismissed because there is no supplemental jurisdiction over that claim.

Result

Defendant's motion to dismiss was granted with prejudice. The court dismissed the ADA claim with prejudice and declined to exercise supplemental jurisdiction over the Unruh Act claim.