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Acheson Hotels, LLC v. Laufer

Supreme Court of the United States · 2023 · Constitutional Law

Constitutional LawArticle IIIMootnessStandingArticle IIImootnessstandingjurisdiction

Facts

Deborah Laufer filed hundreds of ADA suits against hotels whose websites did not state whether they had accessible rooms for disabled guests. The opinion states that she had no thought of staying at the hotels, much less booking a room, and instead systematically searched the web for noncompliant websites and sued to force compliance. After a lower court sanctioned her lawyer for misconduct in other ADA litigation, Laufer voluntarily dismissed her pending suits with prejudice, including this case against Acheson Hotels. She also represented to the Court that she would not file additional ADA tester suits.

Issue

After Laufer voluntarily dismissed her underlying suit with prejudice, should the Supreme Court decide the standing question for which it granted certiorari, or instead treat the case as moot and dispose of it on that basis?

Rule

The Court has authority to address jurisdictional issues of mootness and standing in any order it chooses. When a case before the Court is moot, the Court may vacate the judgment below and remand with instructions to dismiss the case as moot under its established Munsingwear practice.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The Supreme Court grants review in a case from Denver involving whether a nonprofit had Article III standing to challenge a municipal licensing rule. Before argument, the city repeals the rule and both parties agree there is no longer any live dispute, but the respondent still urges the Court to decide standing because that issue was the basis for certiorari.

What is the Court most clearly permitted to do under the governing doctrine?

Explanation. The majority opinion states that mootness and standing are both jurisdictional issues and that the Court may address them in any order it chooses. It therefore may choose the easier ground of mootness and avoid deciding the harder standing issue in a case that is otherwise over. (Derived from Acheson Hotels, LLC v. Laufer (n.d.).)