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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No.

EMILIO PINERO,

Plaintiff, 

v.

RIVER INN SRD LLC.,

Defendant.

________________________________/ 

COMPLAINT

Plaintiff, EMILIO PINERO, by his undersigned counsel, hereby files this Complaint and 

sues, RIVER INN SRD LLC., for injunctive relief pursuant to the Americans with Disabilities

Act, 42 U.S.C. § 12181, et seq., (hereinafter the “A.D.A”), the ADA’s Accessibility Guidelines, 

28 C.F.R. Part 36 (hereinafter the “ADAAG”), and the Florida Building Code.

JURISDICTION

1. This Court has original jurisdiction over the action pursuant to 28 U.S.C., §§1331

and 1343 for Plaintiff’s claims arising under 42 U.S.C. § 12181. et seq., based upon Defendant’s 

violations of Title III of the ADA (see also, 28 U.S.C. §§ 2201 and 2202). As of March 15, 2012, 

Defendant was required to ensure that all of its reservation systems, including its online 

reservation systems (a) identify and describe disabled accessible features of the Hotel in detail; 

(b) identify and describe disabled accessible features of ADA compliant guest rooms in detail; 

(c) permit disabled individuals to independently assess whether the Hotel and its available 

guestrooms meet their individual accessibility needs (by describing accessible and inaccessible 

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features); and (d) allow reservations to be taken for accessible guestrooms in the same manner as 

for non-accessible guestrooms1. Defendant has not complied. This lawsuit follows.

2. This Court has personal jurisdiction over Defendant in this action. Defendant 

owns

or operates the Website, which is an interactive website through which Defendant seeks to 

consummate financial transaction (reservations and payments) with residents of this District (and 

others) who visit the Website, and Defendant violated Plaintiff’s civil rights in this District, as 

set forth more fully below. 

PARTIES

3. Plaintiff, EMILIO PINERO, is a resident of Florida and currently lives in Miami,

and is sui juris. He is a qualified individual with disabilities under the ADA law. Mr. Pinero is a 

double leg amputee from the knees which requires his use of a wheelchair to ambulate. Mr. 

Pinero owns his own vehicle and does drive. He has visited the property, which forms the basis 

of this lawsuit and plan to return to the property to avail himself of the goods and services 

offered to the public at the property, and to determine whether the property has been made ADA 

compliant. His access to the facility and/or full and equal enjoyment of the goods, services, 

facilities, privileges, advantages, and/or accommodations offered therein was denied and/or 

limited because of these disabilities, and will be denied and/or barriers to access and ADA 

violations which exist at the facility, including but not limited, to those set forth in the 

Complaint.

4. Plaintiff is an advocate of the rights of similarly situated disabled persons and,

pursuant to Houston v. Marod Supermarkets, Inc., 733 F.3d 1323 (11th Cir. 2013), is a "tester" 

1 This is a non-exclusive list of requirements imposed by 28 C.F.R. §36.302(e)(l). These requirements apply not 

only to the Website, but also to every online reservation system, including third party websites, on which 

reservations can be made to stay at the Hotel, including orbitz.com, travelocity.com, hotels.com, and others. 

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for the purpose of asserting his civil rights, monitoring, ensuring, and determining whether laces 

of public accommodation, including online reservation systems for places of lodging, are in 

compliance with the ADA.

5. Defendant, RIVER INN SRD LLC, transacts business in the State of Florida and

within this judicial district. Defendant is the owner and/or representative of the owner and/or 

operator of the property, a hotel, which is the subject of this action, located on or about 437 SW 

2

nd Street, Miami, Florida (hereinafter the “facility”).

6. Defendant, RIVER INN SRD LLC, owns and/or operates that certain hotel known

as Selina Miami River, located in Miami, Florida (the “Hotel”). The Hotel has a website located 

at www.selina.com (the “Website”). The Hotel takes reservations through its Website and 

provides information regarding available guestrooms and amenities.

7. The Defendant also allows bookings at third party websites.

8. Defendant, RIVER INN SRD LLC, is the owner and operator of the 

corresponding reservation system found on its website and has control over its content. It also 

has control over the content listed in any third-party reservation providers.

9. The Defendant’s facility is a public accommodation and service establishment, 

and

although required by law to do so, it is not in compliance with the ADA and ADAAG.

10. In this instance, Mr. Pinero visited the facility and encountered barriers to access 

at

the facility, and engaged barriers, suffered legal harm and injury, and will continue to suffer legal 

harm and injury as a result of the illegal barriers to access, and Defendant’s ADA violations set 

forth herein.

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11. Plaintiff has suffered and continues to suffer direct and indirect injury as a result 

of

the ADA violations that exist at the facility and the actions or inactions described herein. 

12. All events giving rise to this lawsuit occurred in the State of Florida. Venue is

proper in this Court as the premises are located in the Southern District. 

FACTUAL ALLEGATIONS AND CLAIM

13. Mr. Pinero has attempted to and has, to the extent possible, accessed the facility, 

but could not do so because of his disabilities due to the physical barriers to access, dangerous 

conditions and ADA violations that exist at the facility that restrict and/or limit his access to the 

facility and/or the goods, services, facilities, privileges, advantages and/or accommodations 

offered therein, including those barriers, conditions and ADA violations more specifically set 

forth in this Complaint.

14. Mr. Pinero intends to visit the facility again in the near future in order to utilize all 

of the goods, services, facilities, privileges, advantages, and/or accommodations commonly 

offered at the facility, but will be unable to do so because of his disability due to the physical 

barriers to access, dangerous conditions and ADA violations that exist at the facility that restrict 

and/or limit his access to the facility and/or accommodations offered therein, including those 

barriers conditions and ADA violations more specifically set forth in this Complaint.

15. Defendant has discriminated against Plaintiff and others with disabilities by 

denying access to, and full and equal enjoyment of the goods, services, facilities, privileges, 

advantages and/or accommodations of the facility, as prohibited by 42 U.S.C., § 12182, et. seq., 

and by failing to remove architectural barriers as required by 42 U.S.C., § 12182(b)(2)(A)(iv), 

and will continue to discriminate against Plaintiff and others with disabilities unless and until 

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Defendant is compelled to remove all physical barriers that exist at the facility, including those 

specifically set forth herein, and make the facility accessible to and usable by persons with 

disabilities, including Plaintiff.

16. Defendant has discriminated against Mr. Pinero by failing to comply with the 

above requirements. A specific, although not exclusive, list of unlawful physical barriers, 

dangerous conditions and ADA violations which preclude and/or limit Plaintiff’s ability (because 

of his disability) to access the facility and/or full and equal enjoyment of the goods, services, 

facilities, privileges, advantages and/or accommodations of the facility include: 

a. Non-compliant disabled parking spaces contrary to the 2010 ADAAG 

Standards 502.

b. Non-compliant exterior accessible routes contrary to the 2010 ADAAG 

Standards 402

c. No ramp access to areas of the property contrary to the 2010 ADAAG 

Standards 502.

d. No handrails on stairs contrary to the 2010 ADAAG.

e. Non-compliant informational and directional signage 703.

f. Lack of policies and procedures to assist persons with disabilities contrary 

to the ADA.

g. No pool lift contrary to the 2010 ADAAG Standards.

h. Non-compliant seating contrary to the 2010 ADAAG Standards 226, 902

i. No lowered section of bar 226 and 902. 

17. The above listing is not to be considered all-inclusive of the barriers, conditions or 

violations encountered by Plaintiff and/or which exist at the facility. Plaintiff requires an 

inspection of the facility in order to determine all of the discriminatory acts violating the ADA. 

18. Mr. Pinero has attempted to gain access to the facility, but because of his 

disability has been denied access to, and has been denied the benefits of services, programs, and 

activities of the facility, and has otherwise been discriminated against and damaged by 

Defendant, because of the physical barriers, dangerous conditions and ADA violations set forth 

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above, and expects to be discriminated against in the future, unless and until Defendant is 

compelled to remove the unlawful barriers and conditions and comply with the ADA. 

19. The removal of the physical barriers, dangerous conditions and ADA violations 

set forth herein is readily achievable and can be accomplished and carried out without much 

difficulty or expense. 42 U.S.C. § 12182(B)(2)(A)(iv); 42 U.S.C. § 12181(9); 28 C.F.R, § 

36.304.

20. Plaintiff is without adequate remedy at law and is suffering irreparable harm, and 

reasonably anticipates that he will continue to suffer irreparable harm unless and until Defendant 

is required to remove the physical barriers, dangerous conditions and ADA violations that exist 

at the facility, including those set forth herein. 

21. The Plaintiff has been obligated to retain undersigned counsel for the filing and 

prosecution of this action. The Plaintiff is entitled to have his reasonable attorney’s fees, costs 

and expenses paid by the Defendant, pursuant to 42 U.S.C., §§ 12205 and 12217.

22. Pursuant to 42 U.S.C. §12188(a), this Court is provided with authority to grant 

injunctive relief to Plaintiff, including an order to alter the subject facility to make it readily 

accessible to and useable by individuals with disabilities to the extent required by the ADA, and 

closing the subject facility until the requisite modifications are completed.

23. On March 15, 2012, the revised regulations implementing Title III of the ADA 

took effect, imposing significant new obligations on inns, motels, hotels and other “places of 

lodging.” 28 C.F.R. §36.302(e)(l) provides that: 

Reservations made by places of lodging. A public accommodation that owns, 

leases (or leases to), or operates a place of lodging shall, with respect to 

reservations made by any means, including by telephone, in-person, or through a 

third party – 

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(i) Modify its policies, practices, or procedures to ensure that individuals 

with disabilities can make reservations for accessible guest rooms during 

the same hours and in the same manner as individuals who do not need 

accessible rooms; 

(ii) Identify and describe accessible features in the hotels and guest rooms 

offered through its reservations service in enough detail to reasonably 

permit individuals with disabilities to assess independently whether a 

given hotel or guest room meets his or her accessibility needs; 

(iii) Ensure that accessible guest rooms are held for use by individuals 

with disabilities until all other guest rooms of that type have been rented 

and the accessible room requested is the only remaining room of that type; 

(iv) Reserve, upon request, accessible guest rooms or specific types of 

guest rooms and ensure that the guest rooms requested are blocked and 

removed from all reservations systems; and 

(v) Guarantee that the specific accessible guest room reserved through its 

reservations service is held for the reserving customer, regardless of 

whether a specific room is held in response to reservations made by 

others. 

24. In promulgating the new requirements, the Department of Justice made clear that 

individuals with disabilities should be able to reserve hotel rooms with the same efficiency, 

immediacy, and convenience as those who do not need accessible guestrooms. 28 C.F.R. Part 

36, Appx. A. 

25. Hotels (and motels) are required to identify and describe all accessible features in 

the hotel and guestrooms; “[t]his requirement is essential to ensure individuals with disabilities 

receive information they need to benefit from the services offered by the place of lodging.” 28 

C.F.R. Part 36, Appx. A. Moreover, “a public accommodation’s designation of a guestroom as 

“accessible” does not ensure necessarily that the room complies with all of the 1991 Standards.” 

28 C.F.R. Part 36, Appx. A. Labeling a guestroom as “accessible” or “ADA” is not sufficient. 

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26. In addition, hotel rooms that are in full compliance with current standards may 

differ, and individuals with disabilities must be able to ascertain which features – in new and 

existing facilities – are included in the hotel’s accessible guest rooms. For example, under certain 

circumstances, an accessible hotel bathroom may meet accessibility requirements with either a 

bathtub or a roll in shower. The presence or absence of particular accessible features such as 

these may mean the difference between a room that is usable by a particular person with a 

disability and one that is not. 28 C.F.R. Part 36, Appx. A. Accordingly, Defendant is required to 

set forth specific accessible features and not merely recite that a guestroom is “accessible” or 

“ADA” or list accessibility features that may (or may not) be offered within a particular room. 

27. For hotels in buildings constructed after the effective date of the 1991 Standards, 

it is sufficient to advise that the hotel itself is fully ADA compliant, and for each accessible 

guestroom, to specify the room type, the type of accessible bathing facility in the room, and the 

communications features in the room. 28 C.F.R. Part 36, Appx. A. 

28. However, for hotels in buildings constructed prior to the 1991 Standards, 

information about the hotel should include, at a minimum information about accessible entrances 

to the hotel, the path of travel to guest check-in and other essential services, and the accessible 

route to the accessible room or rooms. In addition to the room information described above, 

these hotels should provide information about important features that do not comply with the 

1991 Standards. For example, if the door to the “accessible” room or bathroom is narrower than 

required, this information should be included (e.g., door to guest room measures 30 inches clear). 

[emphasis added]. 28 C.F.R. Part 36, Appx. A. 

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29. The Hotel is a place of public accommodation that owns and/or leases and 

operates a place of lodging pursuant to the ADA. The Hotel is in a building constructed prior to 

the 1991 Standards. 

30. The Website (and all other online reservation platforms used by the Hotel) allow 

reservations for the Hotel to be taken online. The Defendant has control over information 

provided to the public about the Hotel through the Website and/or other online platforms. 

31. It is important to Plaintiff that any hotel at which he researches is accessible. 

Plaintiff frequently researches and assesses the accessible features and guestrooms of hotels 

online.

32. While in this District, his home district, Plaintiff visited the Website to learn 

about accessible features of Defendant’s Hotel, to assess whether the Hotel is accessible, and to 

see if he could reserve an accessible room at the Hotel online. Upon his visit, Plaintiff discovered 

that the Website did not provide him with any meaningful accessibility information at all or 

allow for the reservation of an accessible room (with known accessibility features). The Website 

provided information and took reservations related to non-accessible guestrooms, but not 

accessible guestrooms. 

33. The Website homepage and rooms page do not list any ADA accessibility 

information whatsoever or provide any way to reserve ADA accessible rooms or suites.2 Further 

the website indicates that there are “workshops, weekly BBQs, and outdoor music concerts” the 

website does not describe if these events are accessible.

2 Defendant is cautioned against deleting or destroying any version of the Website as it existed on the date of this 

filing, inasmuch as the same may constitute evidence in this lawsuit. All changes and edits should be carefully 

saved, catalogued, and produced.

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34. The Website also has inadequate accessibility information concerning common 

areas and hotel amenities. There is no indication at any point no that the Hotel common areas 

meet the 1991 Standards, or alternatively (as applicable): 

a. Whether the public entrance to the Hotel complies with the 1991 

Standards, and if not, the ways in which it does not comply, so that 

Plaintiff and others similarly situated can evaluate whether it is accessible 

to them; 

b. Whether the registration desk at the Hotel complies with the 1991 

Standards, and if not, the ways in which it does not comply, so that 

Plaintiff and others similarly situated can evaluate whether it is accessible 

to them; 

c. Whether restaurant or other food service areas at the Hotel comply with 

the 1991 Standards, and if not, the ways in which they do not comply, so 

that Plaintiff and others similarly situated can evaluate whether it is 

accessible to them; 

d. Whether any parking facilities, lots, or other parking accommodations at 

the Hotel comply with the 1991 Standards, and if not, the ways in which 

they do not comply, so that Plaintiff and others similarly situated can 

evaluate whether it is accessible to them; 

e. Whether the swimming pool (if any) complies with the 1991 Standards, 

and if not, the ways in which it does not comply, so that Plaintiff and 

others similarly situated can evaluate whether it is accessible to them; 

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f. Whether the business center complies with the 1991 Standards, and if not, 

the ways in which it does not comply, so that Plaintiff and others similarly 

situated can evaluate whether it is accessible to them; 

g. Whether the meeting/ballroom areas comply with the 1991 Standards, and 

if not, the ways in which they do not comply, so that Plaintiff and others 

similarly situated can evaluate whether it is accessible to them; 

h. Whether the route from the public entrance to the registration desk is 

accessible in compliance with the 1991 Standards, and if not, the ways in 

which it does not comply, so that Plaintiff and others similarly situated can 

evaluate whether it is accessible to them; 

i. Whether the route from the registration desk to the accessible rooms is 

accessible in compliance with the 1991 Standards, and if not, the ways in 

which it does not comply, so that Plaintiff and others similarly situated can 

evaluate whether it is accessible to them; 

j. Whether the route from the public entrance to the business center is 

accessible in compliance with the 1991 Standards, and if not, the ways in 

which it does not comply, so that Plaintiff and others similarly situated can 

evaluate whether it is accessible to them; 

k. Whether the route from the accessible guestrooms to the business center is 

accessible in compliance with the 1991 Standards, and if not, the ways in 

which it does not comply, so that Plaintiff and others similarly situated can 

evaluate whether it is accessible to them; 

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l. Whether the route from the public entrance to the pool (if any) is 

accessible in compliance with the 1991 Standards, and if not, the ways in 

which it does not comply, so that Plaintiff and others similarly situated can 

evaluate whether it is accessible to them; 

m. Whether the route from the accessible guestrooms to the pool (if any) is 

accessible in compliance with the 1991 Standards, and if not, the ways in 

which it does not comply, so that Plaintiff and others similarly situated can 

evaluate whether it is accessible to them; 

n. Whether the route from the public entrance to the fitness center is 

accessible in compliance with the 1991 Standards, and if not, the ways in 

which it does not comply, so that Plaintiff and others similarly situated can 

evaluate whether it is accessible to them; 

o. Whether the route from the accessible guestrooms to the fitness center is 

accessible in compliance with the 1991 Standards, and if not, the ways in 

which it does not comply, so that Plaintiff and others similarly situated can 

evaluate whether it is accessible to them; 

p. Whether the route from the public entrance to the restaurant or food 

service areas is accessible in compliance with the 1991 Standards, and if 

not, the ways in which it does not comply, so that Plaintiff and others 

similarly situated can evaluate whether it is accessible to them; q. Whether 

the route from the accessible guestrooms to the restaurant or food service 

areas is accessible in compliance with the 1991 Standards, and if not, the 

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ways in which it does not comply, so that Plaintiff and others similarly 

situated can evaluate whether it is accessible to them; 

r. Whether the route from the public entrance to the conference/ballroom 

space is accessible in compliance with the 1991 Standards, and if not, the 

ways in which it does not comply, so that Plaintiff and others similarly 

situated can evaluate whether it is accessible to them; 

s. Whether the route from any accessible guestrooms to the 

meeting/ballroom space is accessible in compliance with the 1991 

Standards, and if not, the ways in which it does not comply, so that 

Plaintiff and others similarly situated can evaluate whether it is accessible 

to them; 

t. Whether the movie room is accessible in compliance with the 1991 

Standards, and if not, the ways in which it does not comply, so that 

Plaintiff and others similarly situated can evaluate whether it is accessible 

to them; 

35. This is not intended to be an exclusive list, and Plaintiff brings this action to 

remediate all violations of the ADAAG found to exist upon the Website, and upon all online 

reservation platforms used by the Hotel. 

36. In addition to the list above, upon information and belief, Defendant may not 

effectively (i) ensure that accessible guest rooms are held for use by individuals with disabilities 

until all other guest rooms of that type have been rented and the accessible room requested is the 

only remaining room of that type; (ii) reserve, upon request, accessible guest rooms or specific 

types of guest rooms and ensure that the guest rooms requested are blocked and removed from 

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all reservations systems; or (iii) guarantee that the specific accessible guest room reserved 

through its reservations service is held for the reserving customer, regardless of whether a 

specific room is held in response to reservations made by others. Discovery is required on these 

issues.

37. Plaintiff will visit the Website again upon the Defendant’s compliance with the 

laws and regulations specified herein, in order learn about the accessible (and inaccessible) 

features of the Hotel, learn about the accessible (and inaccessible) features of Hotel guestrooms, 

assess the extent to which the hotels meet each of his specific accessibility needs, and determine 

whether he can reserve an accessible guestroom. If the Hotel is the most suited to his 

accessibility needs as compared to other suitable hotels reviewed online. 

38. Defendant has discriminated against Plaintiff and all other mobility-impaired 

individuals, by denying full and equal access to and enjoyment of the goods, services, facilities, 

privileges, advantages and accommodations offered on the Websites, due to the continuing ADA 

and ADAAG violations as set forth above. Defendant has had over eight (8) years to bring the 

Website (and other online reservation platforms, as applicable) into compliance with the 

ADAAG revisions, but has failed or refused to do so. 

39. Modifying the Website (and other online reservation platforms, as applicable) to 

comply with the ADA and ADAAG is accomplishable without undue burden or expense and is 

readily achievable. But in any event, upon information and belief, the Website has been altered, 

updated, and edited, after 2010, but not in a manner compliant with 2010 ADAAG standards. 

40. Defendant will continue to discriminate against Plaintiff and all other disabled 

individuals who access the Website (and other online reservation platforms, as applicable) unless 

and until Defendant modifies the Website (and other online reservation platforms, as applicable) 

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to set forth all required information, as set forth above. 

41. Plaintiff is without an adequate remedy at law and are suffering irreparable harm, 

and Plaintiff reasonably anticipates that he will continue to suffer this harm unless and until 

Defendant is required to correct the ADA violations found upon the Websites (and other online 

reservation platforms, as applicable), and to maintain the Websites (and other online reservation 

platforms, as applicable), inclusive of the online reservation system, and accompanying policies 

and procedures, in a manner that is consistent with and compliant with ADA and ADAAG 

requirements. 

42. Pursuant to 42 U.S.C. §12188(a) this Court has authority to grant injunctive relief 

to Plaintiff, including an Order that compels Defendant to enact policies that are consistent with 

the ADA and its remedial purposes, and to alter and maintain its Website (and other online 

reservation platforms, as applicable), and all online reservation systems, in accordance with the 

requirements set forth within the 2010 Standards, 28 C.F.R. §36.302(e)(l).

WHEREFORE, Plaintiff EMILIO PINERO respectfully requests that the Court 

issue a permanent injunction enjoining Defendant from continuing is discriminatory practices, 

ordering Defendant to remove the physical barriers to access and alter the subject facility to 

make it readily accessible to and useable by individuals with disabilities to the extent required 

by the ADA, closing the subject facility until the barriers are removed and requisite alterations 

are completed, A declaration that the Website (and other online reservation platforms, as 

applicable) is owned, leased, operated, and/or controlled by Defendant is in violation of the 

ADA; Temporary and permanent injunctive relief enjoining Defendant from continuing its 

discriminatory practices, including the requirement that Defendant permanently implement 

policies, practices, procedures, including online content, consistent with the mandates of the 

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2010 ADAAG Standards on its Website (and other online reservation platforms, as applicable); 

Temporary and permanent injunctive relief enjoining Defendant from maintaining or controlling 

content on any website through which it is offering online reservations for any hotel that it owns 

or operates, unless such website and online reservation system fully comply with 28 C.F.R. 

§36.302(e)(l); An award of reasonable attorneys’ fees, costs, disbursements and other expenses 

associated with this action, in favor of Plaintiff; Such other and further relief as this Court 

deems just, necessary and appropriate under the circumstances.

Respectfully submitted,

s/ Glenn R. Goldstein

Glenn R. Goldstein, Esq. (FBN: 55873)

Attorney for Plaintiff

Morales, Goldstein & Barducci, PLLC

150 SE 2nd Ave, Ste. 805

Miami, FL 33131

Ph: 561-573-2106

ggoldstein@g2legal.net

Lauren N. Wassenberg, Esq. (FBN: 34083)

Attorney for Plaintiff

Lauren N. Wassernberg & Associates, P.A.

1825 NW Corporate Blvd, Ste. 110

Boca Raton, Florida 33431

Ph: 561-571-0646

wassenbergl@gmail.com

adalawstaff@gmail.com

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