Garcia

INTRODUCTION

Orlando Garcia sued Zarco Hotels Incorporated (Zarco), the owner and operator of the Hollywood Hotel (the Hotel), under the Americans with Disabilities Act of 1990 (ADA; 42 U.S.C. § 12101 et seq.). Garcia alleged that the Hotel’s reservation website did not provide ADA-required information to enable persons with disabilities to determine whether the Hotel’s common areas and rooms were accessible to them. Zarco moved for summary judgment, submitting printouts from the Hotel’s website with the accessibility information it provided. Garcia then dismissed his case before any opposition was due. The trial court later granted Zarco’s motion for attorney’s fees, finding that Garcia’s action was frivolous as is required to award fees to a prevailing defendant under the ADA. Garcia contends this was error. Garcia fails to demonstrate his claim against Zarco had any arguable merit, and we therefore affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. Garcia’s Complaint Garcia sued Zarco on January 4, 2021. Garcia’s complaint alleged that he is a California resident who suffers from cerebral palsy, has the use of only one arm, and uses a wheelchair, walker, or cane for mobility.…