Tsay Jbr LLC v. United States District Court for the Central District of California

I. Background

Plaintiff Theresa Brooke is a woman with disabilities who uses a wheelchair. Along with her husband, she frequents California hotels to test their compliance with disability access laws. On one such testing trip in August 2023, Brooke and her husband visited the Ramada by Wyndham Burbank Airport, a hotel in Burbank, California. When they arrived, however, architectural barriers allegedly deterred Brooke from entering. Brooke sued the hotel’s owner, Defendant Tsay JBR, LLC, asserting violations of Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. § 12181 et seq., and California’s Unruh Civil Rights Act, Cal. Civ. Code § 51 et seq. (West 2025). The ADA authorizes people with disabilities who are denied “full and equal enjoyment” of “place[s] of public accommodation” to sue for injunctive relief. 42 U.S.C. §§ 12182(a), 12188(a). The Unruh Act similarly creates a private right of action for people with disabilities, along with other enumerated groups, who are

TSAY JBR LLC V. USDC FOR THE CENT. DIST. OF CA 5

denied “full and equal” access to California businesses. See Cal. Civ. Code § 51(b). As part of those protections, the Unruh Act…