Lammey v. JNZ Hospitality, LLC
2:21-cv-00857-WBS-DMC
E.D. Cal.Sep 24, 2021Background
- Plaintiff Dwain Lammey is a quadriplegic wheelchair user who sought to book an accessible room at Motel 6 Chico via the motel’s reservation website.
- Lammey alleged the website failed to describe accessibility features in sufficient detail (e.g., 32" door clearances, bed-side clearance, toilet height/grab bars, sink/mirror clearance, shower type/fixtures).
- Defendant JNZ Hospitality operates the Motel 6 Chico and moved to dismiss under Federal Rule of Civil Procedure 12(b)(6).
- The court granted judicial notice of Motel 6 website screenshots but declined to take judicial notice of unrelated consent decree and plaintiff’s litigation history.
- Applying the DOJ Reservations Rule guidance, the court found the website provided the minimum information required for hotels built to the 1991 standards (including door clear width and room/bath descriptors) and included a phone number for further inquiries.
- The court dismissed the ADA Title III claim for failure to state a claim and, because the Unruh Act claim depended on the ADA claim, dismissed that claim as well.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the motel’s reservation website adequately describes accessible features under the ADA Reservations Rule | Lammey: website lacks required detailed information to allow independent assessment (lists specific features he needs) | Motel 6: website provides sufficient information (room type, bed size/number, bathing facility type, and door width) and a phone number for more detail | Court: website meets DOJ Guidance minimum for hotels built to 1991 standards; ADA claim dismissed |
| Whether DOJ’s nonbinding guidance may be relied on to interpret Reservations Rule | Lammey: DOJ guidance is nonbinding and not exhaustive; more info may be required | Motel 6: DOJ guidance is entitled to deference and compliance with it can satisfy the Reservations Rule | Court: gives deference to DOJ guidance; follows line of district decisions applying it to dismiss similar claims |
| Whether the court may consider the motel website pages on a Rule 12(b)(6) motion | Lammey: authenticity not disputed but accessibility asserted | Motel 6: website pages are central, referenced in complaint, and authenticity is not challenged | Court: may consider website screenshots on motion to dismiss; judicial notice granted for those pages |
| Whether Unruh Act claim stands absent ADA violation | Lammey: brings independent Unruh claim | Motel 6: Unruh claim depends on an underlying ADA violation | Court: because ADA claim dismissed, Unruh claim likewise dismissed |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations insufficient)
- Chapman v. Pier 1 Imports (U.S.) Inc., 631 F.3d 939 (9th Cir. 2011) (Title III ADA discrimination shown by accessibility violations)
- Bragdon v. Abbott, 524 U.S. 624 (1998) (agency interpretation entitled to deference)
- Fortyune v. City of Lomita, 766 F.3d 1098 (9th Cir. 2014) (deference to DOJ interpretation of ADA regulations)
- Daniels-Hall v. National Educ. Ass'n, 629 F.3d 992 (9th Cir. 2010) (when documents referenced in complaint, court may consider them on Rule 12(b)(6) motion)