Deborah Laufer v. Naranda Hotels, LLC, No. 20-2348 (4th Cir. 2023)
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Plaintiff is a self-professed “tester” who has filed hundreds of similar lawsuits throughout the country under Title III of the Americans with Disabilities Act (the “ADA”). Plaintiff complained about hotel reservation websites that do not allow for reservation of accessible guest rooms or provide sufficient accessibility information. Here, the defendant is Naranda Hotels, LLC, the owner of the Sleep Inn & Suites Downtown Inner Harbor in Baltimore. The district court dismissed Laufer’s ADA claim against Naranda for lack of Article III standing to sue.
The Fourth Circuit vacated the district court’s judgment and remanded. The court concluded that Plaintiff’s allegation of an informational injury accords her Article III standing to pursue her ADA claim against Naranda and to seek injunctive relief-whether or not she ever had a definite and credible plan to travel to the Baltimore area. The court also recognized that its decision appears to even the split among the courts of appeals at 3-3 — three circuits that have ruled in Plaintiff’s favor based on an informational or stigmatic injury, and three that have ruled against her and similarly situated plaintiff.
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