Federal Court Dismisses ADA Hotel Website and Facility Lawsuit Over Lack of Standing

On August 20, 2026, the United States District Court for the Northern District of New York granted a motion to dismiss an amended complaint filed against Saratoga Hotel Associates and Driftwood Capital, LLC. The action was dismissed without prejudice, with the court granting 30 days of leave to file a second amended complaint.

Background of the Case

The action was originally brought on October 9, 2025, by an individual resident of Florida with mobility and respiratory impairments alongside the Florida non-profit advocacy organization Access 4 All, Inc. After the defendants filed an initial motion to dismiss, the plaintiffs filed an amended complaint on December 17, 2025.

The plaintiffs alleged violations under Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. § 12182, concerning 29 alleged architectural barriers at the Saratoga Hilton in Saratoga Springs, New York. They also alleged regulatory violations under 28 C.F.R. § 36.302(e)(1), asserting that the hotel's online reservation system (ORS) failed to provide sufficient information regarding accessible features.

Defendants moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) for lack of subject matter jurisdiction and 12(b)(6) for failure to state a claim. On June 24, 2026, the plaintiffs additionally sought leave to amend their complaint to rectify the commercial property address, which had mistakenly cited a different hotel property.

Analysis of Article III Standing

The court addressed jurisdiction under Rule 12(b)(1) and determined that the plaintiffs failed to establish Article III standing for both their physical facility and digital website claims:

• Architectural Barriers: The complaint listed 29 facility barriers but did not link them to specific injuries sustained personally by the plaintiff. The court noted conflicting statements as to whether the individual had stayed at the hotel or had been deterred from staying. While the individual claimed plans to return to the area for events like the June 2026 Belmont Stakes, the court observed that public filings showed similar claims across five other hotel lawsuits during the same event period without concrete reservations at the defendant's specific location.
• Website Reservation System: The complaint stated that the individual visited the site to evaluate compliance with 28 C.F.R. § 36.302(e) rather than with an intent to book a room. Furthermore, allegations that the website contained "insufficient [information] or misinformation" and that the user intended to revisit "in the near future" were ruled vague, conclusory, and lacking concrete, imminent injury.
• Organizational Standing: Because Access 4 All, Inc. asserted claims entirely coterminous with the individual plaintiff without establishing independent injury, the organization likewise failed the requirements for representational standing.

Court Order and Leave to Amend

While expressing concern over "cut-and-paste" litigation traits, the court acknowledged that jurisdictional defects could potentially be cured through more detailed factual pleading.

The court granted the defendants' motion to dismiss without prejudice. The plaintiffs were ordered to file any second amended complaint within 30 days of the August 20, 2026 order, including corrections to the property address and the jurisdictional standing deficiencies. If the plaintiffs do not file within the 30-day period, the court directed the clerk to close the case.

Full case documentation can be reviewed via the U.S. Courts record.