Acheson Hotels v. Laufer
In brief
The Court erased the First Circuit's judgment because the case became moot, without answering the ADA tester-standing question.
- Where it stands
- Decided
Decided 9-0 · December 5, 2023 · Opinion by Justice Barrett
- What it’s about
- This case involved a lawsuit by a disability rights "tester" who sued a hotel for failing to provide accessibility information on its website, despite having no intention of visiting the property.
- Who it affects
- Hotels and disability-rights testers did not receive a Supreme Court answer on when testers may bring these ADA claims. For example, a hotel facing a website-accessibility lawsuit cannot rely on this case to settle the standing question.
Summary: written with AI from the case record.
What it's about
The Supreme Court ultimately vacated the lower court's judgment as moot because the plaintiff voluntarily dismissed her pending lawsuits.
The decision left unresolved a question that has divided federal appeals courts about ADA testers and hotel accessibility information online.
Question presented
Does an ADA “tester” have Article III standing to challenge a hotel’s failure to provide disability accessibility information on its website, even if she has no plans to visit the hotel?
What the Court decided
Holding
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. 50 F. 4th 259, vacated and remanded.
- Result
- Vacated
The vote
From the opinions
“This case is vacated as moot.”
What's next
The case returns to the lower court following the Supreme Court's vacatur. Other courts will continue addressing tester-standing disputes without a Supreme Court answer from this case.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Opinion added: Laufer
Opinion added: opinion
Brief added: Petition
Brief added: Questions Presented
More questions
- What did the Supreme Court rule in Acheson Hotels v. Laufer?
- The Court vacated the First Circuit's judgment as moot and sent the case back. It did not decide whether Laufer had standing to sue.
- Who won Acheson Hotels v. Laufer?
- The hotel obtained vacatur of the First Circuit decision. But the Court did not resolve the central legal question for either side.
- What does Acheson Hotels mean for hotels and ADA testers?
- Hotels and ADA testers still lack a Supreme Court answer on these website-accessibility claims. Similar disputes may continue in lower courts.
- Is the First Circuit's decision still the law after Acheson Hotels?
- No. The Supreme Court vacated the First Circuit's judgment because the case became moot.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.