Macedonia Church v. Lancaster Hotel Ltd. Partnership

[Editor’s Note: Because no one opinion tells the whole story, the account in the casebook is a combined and edited composite of three separate opinions and court documents covering five years of litigation.] Macedonia Church (Macedonia) (plaintiff), a predominantly Black Pentecostal church in Connecticut, sought to reserve lodging at the Lancaster Host Resort and Conference Center (Lancaster Host) for a summer church retreat. In April 2004, Merle Rumble, who oversaw organizing the summer outing, and three other church members visited Lancaster, Pennsylvania. The group met with Bonnie Skagen, a sales representative at Lancaster Host. Skagen later sent a document confirming the number of rooms, dates, and price. Macedonia told the congregation about the lodging and its family-friendly amenities and created a sign-up sheet. Following further conversations, Skagen told Rumble that 40 rooms were not available. Judith Addington, a White friend of the church, then successfully made a reservation for 50 rooms for the same weekend for a fictional Methodist and Congregational church group. The Macedonia group stayed at a Ramada Inn, which lacked the amenities of Lancaster Host, and church members observed drug, prostitution, and violent activity in the area. Macedonia sued the hotel’s owners, Lancaster Hotel Limited Partnership, MASSPA Realty Corporation, and Fine Hotels Corp. (defendants), for discrimination under 42 U.S.C. § 1981, which prohibits race discrimination in the making of contracts. [Editor’s Note: The casebook commentary erroneously refers to 42 U.S.C. § 1983 as 47 U.S.C. § 1983.] Macedonia alleged that Lancaster Host interfered with the ability of Macedonia to contract for rooms by (1) failing to send a contract; (2) failing to communicate that there was any problem with the reservation; and (3) claiming not enough rooms were available. The defendants moved to dismiss the church members, arguing that they lacked standing to be plaintiffs.