Today’s Fourth Circuit opinion in Laufer v. Naranda Hotels, LLC, is worth a look. The Court held the plaintiff’s allegation of an informational injury was enough to confer Article III standing. Here is the intro:
Deborah Laufer, the plaintiff in this civil action on appeal from the District of
Maryland, is a self-professed “tester” who has filed hundreds of similar lawsuits throughout the country under Title III of the Americans with Disabilities Act (the “ADA”), see 42 U.S.C. §§ 12181-12189. Laufer complains of hotel reservation websites that do not allow for reservation of accessible guest rooms or provide sufficient accessibility information. Here, the defendant is Naranda Hotels, LLC, as the owner of the Sleep Inn & Suites Downtown Inner Harbor in Baltimore.
For reasons explained in its Memorandum Opinion of December 2020, the district court dismissed Laufer’s ADA claim against Naranda for lack of Article III standing to sue. See Laufer v. Naranda Hotels, LLC, No. 1:20-cv-02136 (D. Md. Dec. 16, 2020), ECF No. 26 (the “Dismissal Opinion”). In so doing, the court followed local precedents that had been established in separate District of Maryland actions initiated by Laufer. Meanwhile, other district courts and courts of appeals have confronted Laufer’s lawsuits and likewise concluded she could not proceed. Additional federal courts, however, have seen things differently and recognized Laufer’s Article III standing to pursue her ADA claims. Upon careful consideration of the competing views, we are satisfied to join the latter group and thus vacate the district court’s judgment and remand for further proceedings.