A federal court in Louisiana held it lacked personal jurisdiction over a franchisor and its affiliate, finding the franchise agreement did not establish purposeful availment of the forum for purposes of specific personal jurisdiction. Lane v. Baywood Hotels, Inc., 2025 WL 2419727 (E.D. La. Aug. 21, 2025).
Thomas Lane brought suit in Louisiana alleging a hotel owner, its franchisor, and a related affiliate violated the ADA after the hotel charged Lane an additional fee for his service dog and a hotel employee yelled and berated Lane when he brought his service dog into the hotel’s breakfast area. Hilton moved to dismiss for lack of personal jurisdiction, which the court granted.
The core issue was whether certain quality control provisions in Hilton’s franchise agreement established sufficient minimum contacts with the forum for personal jurisdiction. Lane argued that the franchise agreement and training documents established the contacts necessary for personal jurisdiction citing the requirement that Hilton approve the management company that operates the hotel, Hilton’s right to conduct inspections and terminate the franchise, Hilton’s collection of monthly fees, and Hilton’s provision of ADA compliance standards. Finding that franchise agreements or quality control clauses did not, by themselves, establish operational control or conduct directed at the forum for purposes of personal jurisdiction, the district court granted Hilton’s motion to dismiss because the complaint lacked any allegations that Hilton owned, operated, managed, controlled, or had any involvement in the day-to-day operations of the hotel. Further, the court concluded that the existence of ADA compliance standards could not establish sufficient contacts with the forum as Hilton did not direct any discriminatory conduct towards Louisiana through these policies, but instead supplied the hotel with Hilton’s policy to not discriminate.