Laufer v. Arpan LLC, No. 20-14846 (11th Cir. 2022)
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The Eleventh Circuit vacated the district court's dismissal of plaintiff's Americans with Disabilities lawsuit based on lack of Article III standing, concluding that plaintiff has at least alleged an Article III qualifying stigmatic injury. In this case, plaintiff alleged that she suffered a concrete injury when she viewed a hotel's website that omitted accessibility-related information required by federal regulations and as a result, she says, experienced "frustration and humiliation"—even though she admits that she had (and has) no intention to personally visit the hotel.
Despite the absence of a close common-law comparator, the court concluded that under existing precedent plaintiff has alleged a concrete intangible injury. The court explained that plaintiff's allegations satisfy Article III under a narrower reading of Sierra v. City of Hallandale Beach, 996 F.3d 1110 (11th Cir. 2021). Because she claims not only that she suffered illegal discrimination but also that the discrimination resulted in "frustration and humiliation" and a "sense of isolation and segregation," the court concluded that plaintiff has adequately pleaded a concrete stigmatic injury. And because her emotional injury is her emotional injury, it affects her "in a personal and individual way" and is therefore sufficiently particularized. The court remanded for further proceedings.
The court issued a subsequent related opinion or order on April 12, 2023.
The court issued a subsequent related opinion or order on August 15, 2023.
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