Acheson Hotels, LLC v. Laufer - Docket No. 22-429

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The Court vacated the judgment of the Court of Appeals and remanded with instructions to dismiss the case as moot, after Laufer voluntarily dismissed her ADA lawsuit against Acheson Hotels following revelations of misconduct by her attorney in other cases.

Overview

The case of Acheson Hotels, LLC v. Laufer was brought before the Supreme Court to address whether Deborah Laufer had Article III standing to sue hotels for failing to provide information about accessible rooms on their websites, as mandated by the Americans with Disabilities Act (ADA) of 1990. Laufer, who systematically filed lawsuits against numerous hotels without any intention of staying at them, argued that the lack of accessibility information constituted a violation of her rights under the ADA. The case arose amidst a circuit split, with some circuits ruling that Laufer lacked standing while others found she had it. After Laufer's attorney faced sanctions for misconduct, she voluntarily dismissed her pending lawsuits, including the one against Acheson Hotels, leading to a suggestion of mootness in the Supreme Court.

Legal mootness is when a court case no longer needs a decision because the issue has already been resolved or can't be affected by the court's ruling. For example, if two people are arguing over who owns a bike and they both decide to give up the bike, the case is moot because there's no longer a problem to solve.

The issue of vacatur came up in this case too. Vacatur is when a court cancels or sets aside a previous legal judgment or decision. It’s like erasing the court's previous decision as if it never happened. This can occur if the court finds that there was a mistake or if both parties agree to drop the case.

Opinion of the Court

The Supreme Court, in a decision delivered by Justice Barrett, vacated the case as moot. The Court acknowledged its authority to address jurisdictional issues in any order and noted that while Acheson Hotels expressed concern about potential manipulation of the Court's jurisdiction, it was not convinced that Laufer's dismissal was a tactic to evade review. The Court emphasized that Laufer's case was indeed moot due to her voluntary dismissal and that the underlying circuit split on the standing issue remained unresolved. The judgment was remanded to the First Circuit with instructions to dismiss the case as moot, following the precedent established in United States v. Munsingwear, Inc. (1950).

Concurring Opinions

Justice Thomas concurred in the judgment but expressed a desire to address the standing issue directly, arguing that Laufer lacked standing to sue under the ADA. He contended that Laufer's claims did not assert a violation of her rights, as the ADA prohibits discrimination based on disability but does not create a right to information. He criticized Laufer's role as a "tester" of compliance, suggesting that her actions were more aligned with enforcing the law rather than seeking redress for personal harm.

Justice Jackson also concurred in the judgment, agreeing that the case was moot but critiqued the majority's decision to vacate the lower court's judgment. She argued that mootness and vacatur are distinct concepts and that vacatur should not automatically follow from mootness without a specific equitable justification.

Dissenting Opinions

There were no dissenting opinions in this case, but the concurring opinions highlighted differing views on the implications of the Court's decision regarding standing and the vacatur of lower court judgments.

Affected Doctrine

The legal nuance in this case revolves around the doctrine of standing, which requires a plaintiff to demonstrate a concrete injury to have the right to sue in federal court. The ADA allows individuals to sue for discrimination based on disability, but the Court emphasized that it does not create a right to information. Laufer's approach as a "tester" raised questions about whether her lawsuits were genuinely aimed at remedying personal harm or merely enforcing compliance with the law. The case also highlighted the complexities of mootness and vacatur, particularly in how the Court navigates jurisdictional issues and the implications of a party's voluntary dismissal of a case. The majority's decision to vacate the lower court's judgment reflects a longstanding practice aimed at preventing parties from benefiting from favorable judgments that are no longer live controversies, while the concurring opinions raised important considerations about the equitable application of this practice.