Federal Court Grants Marriott Summary Judgment in Website Accessibility Lawsuit

On March 9, 2026, the United States District Court for the Northern District of California granted summary judgment in favor of Marriott International, Inc. in a lawsuit alleging violations of Title III of the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act.

According to the court order, the lawsuit claimed that Marriott's website contained accessibility barriers that prevented blind screen reader users from booking hotel stays. The court concluded both that the plaintiff lacked Article III standing and that the undisputed evidence showed the website complied with ADA requirements for the plaintiff's search.

Background of the Case

The action was originally filed by a previous plaintiff before the current plaintiff, who is legally blind and uses the JAWS screen reader, was substituted as the named plaintiff in May 2025. The plaintiff alleged that between July 1 and July 5, 2022, he attempted to use Marriott's website on a personal computer to reserve a room to visit his son in Tacoma, Washington.

The complaint asserted that on the "Find a Hotel" subpage, the buttons to adjust room and guest counts failed to announce updated values to screen readers, and drop-down menus failed to announce whether they were expanded or collapsed. The plaintiff sought to represent putative nationwide and California classes of blind screen reader users.

Lack of Article III Standing

To establish standing for injunctive relief under the ADA, a plaintiff must demonstrate an injury-in-fact by showing either a genuine intent to return or deterrence from patronizing the facility. The court found the evidence did not support either theory.

The court noted several factual anomalies:

• A neutral forensic examiner appointed by the court found no installation, execution, or use of JAWS on the plaintiff's examined computer, and could not find active browser history records showing visits to Marriott's website.
• The plaintiff had discarded the hard drive used for the search in 2023.
• Phone records showed no communication between the plaintiff and his son, whom he had never visited before and with whom he had not discussed travel plans.
• The plaintiff had only stayed in a hotel once in his life, following an apartment flood in 2017, and had not flown in five to seven years.

The court determined that the plaintiff lacked genuine intent to book or visit a hotel, and therefore could not demonstrate deterrence.

Website Compliance Under the ADA

Independent of standing, the court granted summary judgment because the evidentiary record contradicted the claims of technical barriers.

Demonstration videos using screen readers (both JAWS and NVDA) showed that on both the 2022 and 2025 versions of Marriott's website, the "Find a Hotel" controls announced the default of "1 Room, 1 Guest." Because the plaintiff's stated intent was to book a single room for himself, the default settings allowed the booking path to function.

The court also observed that while Web Content Accessibility Guidelines (WCAG) guide compliance assessments, the ADA does not mandate specific phrasing such as "expanded" or "collapsed" if the auxiliary aid standard is satisfied.

Expert Testimony Rulings

The court partially excluded testimony from the plaintiff's technical expert:

• Excluded a video recreation of the user journey because the expert navigated with a mouse, which does not replicate non-visual keyboard navigation used by blind individuals.
• Excluded predictions that the "vast majority" of blind users take certain navigation pathways, as behavioral claims require distinct expertise and methodology beyond computer science.
• Excluded opinions regarding the 2025 website because the expert mistakenly relied on 2022 archived screenshots.

Because the ADA claim was dismissed, the derivative Unruh Act claim was dismissed as well. Marriott's related motions regarding class certification procedures were denied as moot, and phone record filings were ordered sealed.