Acheson Hotels v. Laufer
The Application
Laufer, a serial ADA tester targeting hundreds of hotels without intending to visit them, argued the ADA's accessibility requirements created enforceable rights; the hotels contended this posed only an abstract grievance without concrete injury, exemplifying the circuit disagreement over whether testers can vindicate statutory compliance through enforcement actions.
The Conclusion
The Supreme Court dismissed the case as moot in December 2023 after Laufer voluntarily dismissed her claims following her attorney's suspension, leaving the standing question unresolved and the circuit split on tester standing unaddressed.
No circuit court data for this case.
Case Analysis
Overview
Deborah Laufer, a serial ADA tester with disabilities, sued hundreds of hotels for failing to include accessibility information on their reservation websites, information the ADA regulations require, even though she had no plans to visit any of those hotels. The hotels challenged her standing to sue, arguing she suffered no concrete injury. The Supreme Court dismissed the case as moot in December 2023 after Laufer's attorney was suspended for misconduct and she voluntarily dismissed her claims, leaving the standing question unresolved. The case arrived at the Court as a vehicle for limiting 'tester' standing, and leaving without a decision means the circuits remain split on whether ADA testers with no travel plans can bring enforcement suits.
Issue
Whether an ADA tester with a disability lacks Article III standing to sue hotels for failing to provide legally-required accessibility information on reservation websites when the tester has no concrete plans to visit any of the defendant hotels.
Rule
A plaintiff must establish Article III standing by demonstrating a concrete and particularized injury in fact, causation, and redressability; the ADA requires hotels to provide accessibility information on their websites, and circuits have split on whether a tester's enforcement interest, absent concrete travel plans, constitutes sufficient injury.
Analysis
Laufer, a serial ADA tester targeting hundreds of hotels without intending to visit them, argued the ADA's accessibility requirements created enforceable rights; the hotels contended this posed only an abstract grievance without concrete injury, exemplifying the circuit disagreement over whether testers can vindicate statutory compliance through enforcement actions.
Conclusion
The Supreme Court dismissed the case as moot in December 2023 after Laufer voluntarily dismissed her claims following her attorney's suspension, leaving the standing question unresolved and the circuit split on tester standing unaddressed.
Notes
OT2023. Added via SCOTUS bulk import 2026-05-14
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