Acheson Hotels, LLC v. Laufer, 601 U.S. ___ (2023)
Deborah Laufer has filed numerous lawsuits against hotels for not providing information on their websites about the availability of rooms accessible to disabled individuals, as required by the Americans with Disabilities Act (ADA). Laufer's actions have led to a split among the circuit courts, with the Second, Fifth, and Tenth Circuits ruling that she lacks standing to sue, while the First, Fourth, and Eleventh Circuits have ruled in her favor. The case at hand was brought to the Supreme Court by Acheson Hotels, LLC, from the First Circuit to resolve this split.
After the Supreme Court granted review, Laufer's lawyer was suspended by the United States District Court for the District of Maryland for fraudulent practices. Following this, Laufer voluntarily dismissed her pending lawsuits, including the one against Acheson. She then suggested to the Supreme Court that her case was moot. Acheson, however, argued that the standing issue, which was the reason the case was brought to the Supreme Court, should be resolved for the sake of efficiency and to prevent future manipulation of the Court's jurisdiction.
The Supreme Court, while acknowledging Acheson's concerns, ruled that Laufer's case against Acheson was moot and dismissed it on that ground. The Court emphasized that it might exercise its discretion differently in a future case. The judgment was vacated, and the case was remanded to the United States Court of Appeals for the First Circuit with instructions to dismiss the case as moot.
(The Supreme Court dismissed this case as moot without reaching the substantive issues that it raised.)
SUPREME COURT OF THE UNITED STATES
Syllabus
Acheson Hotels, LLC v. Laufer
certiorari to the united states court of appeals for the first circuit
No. 22–429. Argued October 4, 2023—Decided December 5, 2023
The Court granted review in this case to consider whether Deborah Laufer has Article III standing to sue hotels whose websites failed to state whether they have accessible rooms for the disabled as required by the Americans with Disabilities Act of 1990, even if Laufer had no thought of staying at the hotels, much less booking a room. After a lower court sanctioned her lawyer, Laufer voluntarily dismissed her pending suits, including her case against Acheson Hotels, LLC, and filed a suggestion of mootness in this Court. Though Laufer’s case is moot, the circuit split on the issue briefed and argued in this Court is very much alive.
Held: This case is vacated as moot. The Court has the authority to address jurisdictional issues of mootness and standing in any order it chooses. See Sinochem Int’l Co. v. Malaysia Int’l Shipping Corp., 549 U.S. 422, 431. And while the Court is sensitive to Acheson’s concern about litigants manipulating this Court’s jurisdiction, the Court is not convinced that Laufer abandoned her case in an effort to evade the Court’s review. Pp. 2–3.
50 F. 4th 259, vacated and remanded.
Barrett, J., delivered the opinion of the Court, in which Roberts, C. J., and Alito, Sotomayor, Kagan, Gorsuch, and Kavanaugh, JJ., joined. Thomas, J., and Jackson, J., filed opinions concurring in the judgment.
Judgment issued. |
Judgment VACATED and case REMANDED. Barrett, J., delivered the opinion of the Court, in which Roberts, C. J., and Alito, Sotomayor, Kagan, Gorsuch, and Kavanaugh, JJ., joined. Thomas, J., and Jackson, J., filed opinions concurring in the judgment. |
Letter and attached opinion of lower court in related litigation before CA4 filed by respondent. (Distributed) |
Letter of Deborah Laufer submitted. |
Argued. For petitioner: Adam G. Unikowsky, Washington, D. C. For United States, as amicus curiae: Erica L. Ross, Assistant to the Solicitor General, Department of Justice, Washington, D. C. For respondent: Kelsi B. Corkran, Washington, D. C. |
Supplemental Brief of Deborah Laufer submitted. |
Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument GRANTED. |
Reply of petitioner Acheson Hotels, LLC filed. (Distributed) |
Reply of Acheson Hotels, LLC submitted. |
Letter of respondent Deborah Laufer updating the Clerk on status of her related lower court cases filed (Corrected letter received 9/25/23). |
Letter of respondent Deborah Laufer updating the Clerk on status of her related lower court cases filed (Corrected letter filed). |
Supplemental Brief of Deborah Laufer submitted. |
Letter from respondent updating the Clerk on status of her related lower court cases of Deborah Laufer submitted. |
Amicus brief of Disability Rights Education & Defense Fund, et al. submitted. |
The respondent’s request that the Court dismiss the case as moot at this time is denied. The question of mootness will be subject to further consideration at oral argument in addition to the question presented. |
Amicus brief of Philip L. Schuler, Jenny Rodriguez-Fee and Michael M. Epstein, in association with the Amicus Project submitted. |
Amicus brief of Massachusetts, et al. submitted. |
Amicus brief of Philip L. Schuler, Jenny Rodriguez-Fee and Michael M. Epstein, in association with the Amicus Project submitted. |
Amicus brief of Philip L. Schuler, Jenny Rodriguez-Fee and Michael M. Epstein, in association with the Amicus Project submitted. |
Amicus brief of NAACP Legal Defense and Educational Fund, et al. submitted. |
Amicus brief of Public Citizen submitted. |
Amicus brief of Constitutional Accountability Center submitted. |
Brief amici curiae of NAACP Legal Defense and Educational Fund, et al. filed. (Distributed) |
Amicus brief of Fair Housing Organizations and Testers submitted. |
Amicus brief of Disability Antidiscrimination Law Scholars submitted. |
Amicus brief of Disability Rights Education & Defense Fund, et al. submitted. |
Brief amicus curiae of Public Citizen filed. (Distributed) |
Amicus brief of Disability Rights Education & Defense Fund, et al. not accepted for filing.(Corrected version submitted) (August 18, 2023) |
Amicus brief of Disability Rights Education & Defense Fund, et al. not accepted for filing. (Corrected version submitted - August 18, 2023) |
Brief amicus curiae of Constitutional Accountability Center filed. (Distributed) |
Brief amici curiae of Disability Rights Education & Defense Fund, et al. filed. (Distributed) |
Brief amici curiae of Disability Rights Education & Defense Fund, et al. filed. (Distributed) |
Brief amici curiae of Philip L. Schuler, et al. in association with the Amicus Project filed. (Distributed) |
Brief amici curiae of Disability Rights Education & Defense Fund, et al. filed. |
Brief amici curiae of Fair Housing Organizations and Testers, et al. filed. (Distributed) |
Brief amici curiae of Disability Antidiscrimination Law Scholars filed. (Distributed) |
Amicus brief of Disability Rights Education & Defense Fund, et al. submitted. |
Brief amici curiae of Massachusetts, et al. filed. (Distributed) |
Brief amici curiae of Philip L. Schuler, et al. filed. (Distributed) |
Motion of United States for leave to participate in oral argument and for divided argument submitted. |
Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument filed. |
Brief of Deborah Laufer submitted. |
Brief of respondent Deborah Laufer filed. (Distributed) |
Petitioner’s Opposition to Suggestion of Mootness of Acheson Hotels, LLC submitted. |
Petitioner’s Opposition to Suggestion of Mootness filed. (Distributed) |
CIRCULATED |
Suggestion of Mootness of Deborah Laufer submitted. |
Suggestion of mootness filed by respondent Deborah Laufer. |
Record received from the United States Court of Appeals for the First Circuit. The record is electronic and available on PACER. |
Complete record on appeal from the United States District Court for the District of Maine electronically received and available with the Clerk. |
Record requested from the United States Court of Appeals for the First Circuit. |
SET FOR ARGUMENT on Wednesday, October 4, 2023. |
Amicus brief of The Buckeye Institute, Maine Policy Institute, Job Creators Network Foundation, National Real Estate Investors Association, and Ohio Hotel and Lodging Association submitted. |
Amicus brief of Restaurant Law Center submitted. |
Amicus brief of National Association of Homebuilders submitted. |
Amicus brief of Chamber of Commerce of the United States of America, American Resort Development Association, National Association of Home Builders of the United States, and International Council of Shopping Centers submitted. |
Amicus brief of Center for Constitutional Responsibility submitted. |
Amicus brief of Retail Litigation Center, Inc., and National Retail Federation submitted. |
Amicus brief of Atlantic Legal Foundation & DRI Center for Law and Public Policy submitted. |
Amicus brief of United States submitted. |
Brief amici curiae of Chamber of Commerce of the United States of America, et al. filed. |
Brief amicus curiae of United States in support of neither party filed. |
Brief amici curiae of Retail Litigation Center, Inc., et al. filed. |
Brief amicus curiae of National Association of Homebuilders filed. |
Brief amici curiae of The Buckeye Institute, et al. filed. |
Brief amicus curiae of Center for Constitutional Responsibility filed. |
Brief amici curiae of Atlantic Legal Foundation, et al. filed. |
Brief amici curiae of Restaurant Law Center, et al. filed. |
Brief of Acheson Hotels, LLC submitted. |
Joint Appendix submitted. |
Brief of petitioner Acheson Hotels, LLC filed. |
Joint appendix filed. (Statement of costs filed) |
Motion to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioner's brief on the merits is extended to and including June 5, 2023. The time to file respondent's brief on the merits is extended to and including August 2, 2023. |
Motion of Acheson Hotels, LLC for an extension of time submitted. |
Motion for an extension of time to file the briefs on the merits filed. |
Petition GRANTED. |
DISTRIBUTED for Conference of 3/24/2023. |
DISTRIBUTED for Conference of 3/17/2023. |
Reply of petitioner Acheson Hotels, LLC filed. (Distributed) |
Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioner. |
Brief of respondent Deborah Laufer in opposition filed. |
Motion to extend the time to file a response from February 17, 2023 to March 3, 2023, submitted to The Clerk. |
Motion to extend the time to file a response is granted in part and the time is further extended to and including February 27, 2023. |
Motion to extend the time to file a response is granted and the time is extended to and including February 17, 2023. |
Motion to extend the time to file a response from January 18, 2023 to February 17, 2023, submitted to The Clerk. |
Response Requested. (Due January 18, 2023) |
DISTRIBUTED for Conference of 1/6/2023. |
Brief amicus curiae of DRI Center for Law and Public Policy filed. |
Brief amici curiae of Restaurant Law Center, et al. filed. |
Brief amicus curiae of Center for Constitutional Responsibility filed. |
Brief amici curiae of Retail Litigation Center, Inc., et al. filed. |
Brief amici curiae of Chamber of Commerce of the United States of America, et al. filed. |
Waiver of right of respondent Deborah Laufer to respond filed. |
Petition for a writ of certiorari filed. (Response due December 8, 2022) |