Laufer v. Acheson Hotels, LLC, No. 21-1410 (1st Cir. 2022)
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The First Circuit reversed the judgment of the district court dismissing Plaintiff's claim brought under the Americans with Disabilities Act (ADA) against Defendant, which operated an inn on Maine's southern coast, for lack of subject-matter jurisdiction, holding that Plaintiff had Article III standing to bring her suit.
Plaintiff, who was disabled and a self-proclaimed ADA "tester" who brought hundreds of other ADA suits around the country, brought a single claim against Defendant for violation of 42 U.S.C. 12181 and 28 C.F.R. 36.302(e), alleging that Defendant's website didn't identify accessible rooms or provide an option for booking an accessible room. Defendant filed a motion to dismiss, alleging that Plaintiff had no real intention of booking a room at its inn, and therefore, Plaintiff lacked Article III standing to bring her suit. The district court granted the motion to dismiss. The First Circuit reversed, holding that the district court had Article III jurisdiction over this case.
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