Acheson Hotels, LLC v. Laufer

In Acheson Hotels, LLC v. Laufer, decided on December 5, 2023, by the United States Supreme Court, plaintiff Deborah Laufer, a self-appointed ADA tester, sued Acheson Hotels, LLC in federal court in Maine. Laufer alleged that the hotel's website failed to provide accessibility information required by ADA regulations, even though she had no intention of booking a room. The district court dismissed for lack of standing, but the First Circuit reversed. After the Supreme Court granted certiorari, Laufer voluntarily dismissed her pending suits and filed declarations stating she would not file additional lawsuits. The Supreme Court ruled the case was moot, vacated the First Circuit's judgment, and remanded with instructions to dismiss, without deciding the standing question.

The Supreme Court vacated the First Circuit's judgment and remanded with instructions to dismiss the case as moot, because Deborah Laufer voluntarily dismissed her underlying complaints and submitted declarations that she would not pursue further lawsuits. The Court did not resolve the circuit split on ADA tester standing.

Whether a self-appointed ADA tester who has no intention of booking a hotel room has Article III standing to sue for website accessibility violations, and whether the case became moot after the plaintiff voluntarily dismissed her claims during Supreme Court review.

The decision avoided a definitive ruling on ADA tester standing, leaving businesses exposed to serial website accessibility lawsuits and preserving uncertainty across federal circuits. It also highlighted the Court's reluctance to decide constitutional standing issues when a plaintiff can moot a case voluntarily.