APPELGREN v. ISLAND HOSPITALITY MANAGEMENT VII, LLC
2:24-cv-08009
D.N.J.May 19, 2025Background
- Plaintiff, a Treasury Special Agent with severe anxiety-related conditions, attempted to stay at the Hampton Inn and Suites in Newark-Harrison, NJ, in September 2023.
- Plaintiff alleges he faced unnecessary delays, hostile staff, and a chaotic lobby, triggering a panic attack and exacerbating his medical issues.
- Plaintiff did not finish checking in or use his hotel room and attempted to complain to management with no relief.
- He claims his travel and professional abilities have suffered following the incident, allegedly due to defendants’ failure to accommodate his disabilities.
- Plaintiff's second amended complaint named Island Hospitality and Hilton as defendants, asserting federal ADA/FHA claims and various state law claims; Hilton's role as franchisor was disputed.
- Defendants moved to dismiss for lack of personal jurisdiction over Hilton and failure to state a claim under Rule 12(b)(6).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over Hilton | Hilton controls hotel as franchisor, linking it to NJ hotel | Hilton is not franchisor, no sufficient contacts with NJ hotel | No personal jurisdiction over Hilton; complaint dismissed |
| ADA/FHA violation (reasonable accommodation) | Hotel failed to accommodate disabilities, causing harm | Plaintiff never informed staff of disabilities/needed accommodations | No plausible claim; defendants not aware of disability |
| Damages under Title III ADA | Entitled to compensatory/punitive damages for discrimination | Title III does not permit such damages | Title III allows only injunctive relief, not damages |
| Supplemental state claims | State claims should stay if federal claims dismissed | No jurisdiction if federal claims dismissed | No supplemental jurisdiction after federal claims dismissed |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (complaint must state a claim for plausible relief)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility requirement for pleadings)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (personal jurisdiction standards)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (test for specific jurisdiction)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (minimum contacts standard for jurisdiction)