Acheson Hotels, LLC v. Laufer
601 U.S. 1 (2023)
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Rule of Law:
The Supreme Court has the discretion to address jurisdictional issues such as mootness and standing in any order it chooses and may dismiss a case as moot even when a significant, unresolved circuit split on standing exists.
Facts:
- Deborah Laufer, a person with disabilities who uses a wheelchair, is a self-described 'tester' of compliance with the Americans with Disabilities Act (ADA).
- Laufer systematically searches the internet to find hotel websites that fail to provide accessibility information as required by a federal regulation known as the Reservation Rule.
- Laufer visited the website of the Coast Village Inn, a hotel in Maine owned by Acheson Hotels, LLC, which did not contain the required accessibility information.
- Laufer had no intention of booking a room at or visiting the Coast Village Inn or traveling to Maine.
- Laufer has filed over 600 similar lawsuits against hotels across the country.
- After the Supreme Court agreed to hear this case, a lower court sanctioned one of Laufer's attorneys for professional misconduct in unrelated but similar ADA cases.
- Following the sanction of her attorney, Laufer voluntarily dismissed all her pending ADA lawsuits with prejudice, including her case against Acheson.
Procedural Posture:
- Deborah Laufer sued Acheson Hotels, LLC in the U.S. District Court for the District of Maine.
- The District Court (a trial court) dismissed the complaint, ruling that Laufer lacked Article III standing to sue.
- Laufer, as appellant, appealed the dismissal to the U.S. Court of Appeals for the First Circuit.
- The First Circuit (an intermediate appellate court) reversed the District Court, holding that Laufer did have standing.
- Acheson Hotels, LLC, as petitioner, filed a petition for a writ of certiorari with the U.S. Supreme Court.
- The Supreme Court granted the petition for a writ of certiorari to resolve a circuit split on the standing issue.
- After certiorari was granted, Laufer voluntarily dismissed her claim against Acheson in the District Court and filed a suggestion of mootness in the Supreme Court.
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Issue:
Should the Supreme Court dismiss this case as moot after the plaintiff voluntarily dismissed her underlying claim with prejudice, or should it proceed to resolve the circuit split on the antecedent jurisdictional question of Article III standing for which certiorari was granted?
Opinions:
Majority - Justice Barrett
Yes, the case is moot and should be dismissed on that ground. The Court possesses the authority to resolve jurisdictional issues in any order and chooses to address mootness first. Although the Court is sensitive to the petitioner's concern about litigants manipulating its jurisdiction, it is not convinced that Laufer abandoned her case in an effort to evade review, as her dismissal followed the sanctioning of her lawyer. The Court exercises its discretion to dismiss on grounds of mootness but emphasizes that it might exercise this discretion differently in a future case to deter strategic behavior. The judgment of the First Circuit is vacated, and the case is remanded with instructions to dismiss as moot, following the practice established in United States v. Munsingwear, Inc.
Concurring in the judgment - Justice Thomas
No, the Court should not have dismissed the case as moot but should have decided the important and recurring question of standing. The standing issue is logically antecedent to mootness, and Laufer's eleventh-hour dismissal is a transparent tactic for evading review that should not be rewarded. On the merits of the standing question, Laufer lacks standing because she has not suffered a violation of her own rights. The ADA prohibits discrimination, but it does not create a freestanding right to information for a 'tester' who has no intention of visiting the hotel. By suing, Laufer improperly acts as a private attorney general, a role reserved for the Executive Branch.
Concurring in the judgment - Justice Jackson
Yes, the case is moot and should be dismissed, but the Court's decision to also vacate the lower court's judgment warrants separate consideration. Mootness and vacatur are distinct legal concepts. Vacatur is an extraordinary equitable remedy that should not automatically follow a finding of mootness but should be based on a particularized assessment of fairness and the circumstances of the case. A party's mere inability to appeal is not, by itself, a sufficient harm to justify vacating a presumptively valid lower court judgment. However, I concur in the judgment of vacatur here solely because it is consistent with the Court's established practice when mootness is caused by the unilateral action of the party who prevailed below.
Analysis:
This decision leaves a significant circuit split on ADA 'tester' standing unresolved, ensuring the issue will likely return to the Court. By explicitly choosing to dismiss for mootness while reserving the right to act differently in the future, the Court issued a warning against strategic dismissals intended to manipulate its docket. The case is also notable for Justice Jackson's concurrence, which questions the Court's long-standing practice of automatically vacating lower court judgments in mooted cases, suggesting a potential future re-examination of the Munsingwear doctrine. The decision provides temporary relief to businesses facing tester lawsuits in some circuits but offers no long-term legal clarity on the central issue.
