## Facts

- Deborah Laufer, a Florida resident with disabilities, described herself as an ADA “tester” who reviews hotel reservation websites for required accessibility information.
- Acheson Hotels, LLC operated hotels in Maine subject to Title III of the Americans with Disabilities Act (ADA) and related reservation-website accessibility regulations.
- Laufer visited Acheson’s online reservation information and alleged it failed to disclose required accessibility details about accessible rooms and features.
- Laufer sued in federal court seeking injunctive relief and attorney’s fees, while conceding she had no intention of booking a room or staying at the hotels.
- While the case was pending before the Supreme Court, Laufer voluntarily dismissed this and her other similar ADA suits with prejudice and represented she would not refile similar suits; she then suggested the case was moot.

## Issues

1. Whether the dispute remained a live Article III case or controversy after Laufer’s voluntary dismissal with prejudice and representations abandoning similar claims.
2. Whether the Supreme Court should decide Article III standing for ADA “tester” plaintiffs notwithstanding mootness concerns.
3. If moot, whether vacatur of the court of appeals’ judgment was the proper disposition.

## Decision

- The Court held the case was moot.
- The Court vacated the First Circuit’s judgment and remanded.
- The Court declined to decide whether an ADA “tester” who lacks intent to patronize the hotel has Article III standing.
- The Court was not persuaded that Laufer’s dismissal was an effort to evade review sufficient to keep the case.
- Justice Thomas concurred in the judgment, stating he would have reached standing and found no Article III standing.
- Justice Jackson concurred in the judgment, questioning routine vacatur when mootness results from unilateral action by the prevailing party but following existing practice.

## Legal Principles

- Federal courts may address jurisdictional questions (including mootness and standing) in the order they choose.
- A case becomes moot when intervening events eliminate a live dispute so that the court cannot grant effective relief.
- When mootness occurs through unilateral action of the party who prevailed below, the Court generally vacates the lower-court judgment to prevent it from having continuing legal effect.
- Vacatur in mootness settings is a remedial, equitable practice applied according to the Court’s precedents.

## Conclusion

The Supreme Court disposed of the case on mootness after the plaintiff dismissed her claims with prejudice, vacated the court of appeals’ standing ruling, and left unresolved the divided lower-court authority on whether ADA website “testers” without intent to book or stay have Article III standing.


Acheson Hotels, LLC v. Laufer, 601 U.S. 1 (2023)