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extreme Litigation Risk — 85.7% Pre-1990 Building Stock

Hotel ADA Compliance in Century City

9 hotels across 6 commercial corridors. With 85.7% of buildings constructed before 1990 and an average build year of 1988, Century City hotels face significant ADA compliance challenges.

9
Hotel Properties
85.7%
Built Before 1990
extreme
Litigation Risk
$3K–$52K
Typical Settlement
CASp #991Built Ronald Reagan UCLA Medical CenterMS Structural EngineeringTutor Perini Veteran$1M Insured

City Intelligence Brief

Century City has 9 hotels, 85.7% built before 1990 (avg. year 1988), concentrated along Avenue of the Stars. Hotel ADA litigation risk is extreme in Century City, with settlements reaching $52K — accessible room count deficiency is the leading trigger. Century City's 10.8% disability rate and 13.4% senior population create above-average demand for accessible hotels. Los Angeles Department of Building and Safety (LADBS) oversees ADA compliance for Century City's hotels, with 4 local programs supporting accessibility upgrades.

Building Stock Analysis

Hotel Building Stock in Century City

Century City's Avenue of the Stars corridor has 85.7% pre-1990 hotels with an average build year of 1988, making accessible room count deficiency especially common.

An analysis of hotel properties in Century City, including building age, square footage, and key commercial corridors.

9

Hotel Properties

2.49M

Total Sq Ft

85.7%

Built Before 1990

1988

Avg Year Built

Typical Era: 1966 (reopened 2021)

Key Corridors

Century Park East / Century Plaza Cluster

Home to the Century Plaza Towers (1975, ~2.3M SF twin office towers), the Fairmont Century Plaza hotel (1966, reopened 2021 as part of a $2.5B mixed-use redevelopment with 400 rooms), and Century Park Plaza office building (1972, 373,900 SF). This cluster concentrates the district's largest pre-1990 floor area. ADA risk centers on campus-scale routing between towers, hotel, structured parking, and passenger loading zones. Elevated plazas, porte-cochère grade transitions, and legacy garage-to-lobby accessible routes are recurring compliance concerns.

Showing corridors most relevant to Hotels. 6 total corridors in Century City.

Notable Buildings

Century Park Plaza

Century Park East

Built 1972

373,900 sq ft

Fairmont Century Plaza

2025 Avenue of the Stars

Built 1966

Litigation Intelligence

ADA Litigation Risk for Hotel in Century City

With a extreme litigation risk and settlements reaching $52K, hotels in Century City face significant ADA exposure — Hotels operating in California—particularly in Los Angeles County—face **extreme** litigation risk.

Litigation Risk Level

extreme

Hotels operating in California—particularly in Los Angeles County—face **extreme** litigation risk. The combination of federal ADA Title III exposure, California's Unruh Civil Rights Act ($4,000 minimum statutory damages per violation per visit), and aggressive serial plaintiff activity creates a uniquely hostile litigation environment. Hotels present an outsized target surface because they must comply with accessible room ratio requirements, reservation system accessibility rules (28 CFR §36.302(e)), pool and spa lift mandates, common area access standards, and website accessibility for online booking—each representing an independent avenue for lawsuits. The DOJ has specifically and repeatedly targeted hotels in enforcement sweeps, including the landmark 2024 Marriott settlement and the 2021 Southern California 27-hotel initiative.

Typical Settlement Range

$2,500 – $51,500

Most Targeted Property Types

Retail StoreRestaurantMedical OfficeHotelParking Facility

Plaintiff Firms Targeting Hotels

FirmFocusVolume
So Cal Equal Access Group (Jason Kim, Jason Yoon)Physical access barriers, hotels, retail2,598 federal ADA Title III lawsuits in 2024 alone
Potter Handy LLP / Center for Disability AccessHotel reservation websites565+ hotel-specific cases
Theresa Brooke / Peter Strojnik (The Strojnik Firm LLC)Hotel parking, loading zones, physical access168 hotel cases in LA/Beverly Hills area
Orlando GarciaHotel reservation system complianceHundreds of similar lawsuits in California; lost and ordered to pay $57,604.90 in fees in *Garcia v. Zarco Hotels*
Traci MorganHotel website accessibilitySerial plaintiff; lost and ordered to pay $55,414.84 in fees in *Morgan v. Zarco Hotels*

ADA Violations & Risk Profile for Hotels

1

Accessible Room Count Deficiency

ADA §224.2 / CBC 11B-224.2ADA §224.2; CBC 11B-224.2; CBC 11B-607; CBC 11B-608.2.1; CBC 11B-608.2.2

Hotels must provide a specific number of mobility-accessible guest rooms proportional to total room inventory. Many older hotels, especially pre-1990 properties, lack the required number. For example, a 100-room hotel needs 5 total accessible rooms (4 without roll-in showers + 1 with roll-in shower).

Regulatory Context

Under ADA §224.2 and CBC 11B-224.2, the required number of accessible guest rooms scales with total room inventory: Rooms without roll-in showers must provide either an accessible bathtub (CBC 11B-607) or a transfer-type shower (CBC 11B-608.2.1). Roll-in shower rooms must have a standard or alternate roll-in shower (CBC 11B-608.2.2/11B-608.2.3) with a folding seat.

$15,000–$48,000Very High — cited in CCDA top-10 violations as "Access to Goods, Support, Services, and Equipment: Accessible lodging units are non-existent, inaccessible, or insufficient in quantities"
2

Non-Compliant or Missing Accessible Parking

ADA §502 / CBC 11B-502; Table 208.2ADA §407.

Parking lots must contain the minimum number of accessible spaces. California requires 2 accessible spaces per 25 total (stricter than the federal 1 per 25). One in every six accessible spaces must be van-accessible. Hotels frequently fail on slope, striping, signage, access aisle width, or proximity to entrance.

Regulatory Context

An unbroken accessible route must connect from the accessible parking spaces and passenger loading zones through the hotel entrance, lobby, front desk, elevators (if applicable), and corridors to all accessible guest rooms and common areas (pool, fitness center, restaurant, meeting rooms). Routes must maintain 36" minimum clear width (48" preferred), have compliant thresholds (½" maximum), proper door hardware, and elevator cab dimensions per ADA §407. *

$500–$2,000Very High — "Parking: Existing spaces are non-compliant" ranked #1 in CCDA violations for July–December 2024 with 633 complaints; parking signage and loading zones also in the top 10
3

Exterior and Interior Path-of-Travel Barriers

ADA §206 / CBC 11B-206; §403

Accessible routes must connect parking areas through the lobby to accessible guest rooms without barriers. Common deficiencies include uneven surfaces, excessive slope/cross-slope, lack of detectable warnings, non-compliant thresholds, and missing curb ramps. Hotels with multi-building layouts and older construction are especially vulnerable.

$2,000–$15,000Very High — "Exterior Path of Travel – Pathway" ranked #2 and "Interior Path of Travel" ranked #5 in CCDA top-10 violations
4

Pool Lift and Spa Accessibility Deficiency

ADA §242, §1009 / CBC 11B-242, 11B-1009

All hotel pools and spas must have fixed pool lifts or sloped entries since January 31, 2013. Pool lifts must accommodate 300+ lbs, submerge to 18" minimum, have a seat height of 17–19", and be independently operable. Many hotels still lack compliant lifts or have non-functional equipment. Pool lift lawsuits are particularly prolific in California.

Regulatory Context

All hotel pools require at least one accessible means of entry—typically a fixed pool lift or sloped entry. Spas require a pool lift, transfer wall, or transfer system. Pool lifts must be fixed to the deck, accommodate 300+ lbs, have operable controls from the deck and water, and be independently usable without staff assistance.

$3,000–$8,000High — described as "heavily litigated across California" and a frequent serial plaintiff target
5

Bathroom/Shower Non-Compliance in Accessible Rooms

ADA §608, §607 / CBC 11B-608, 11B-607

Accessible guest room bathrooms must meet exact specifications for roll-in or transfer showers, grab bar placement, turning radius, toilet clearance, sink height, and door swing. Hotels with 51+ rooms must provide a specific number of roll-in shower rooms. CASp inspectors verify measurements down to the inch—a grab bar off by one inch triggers a violation.

$4,000–$12,000High — one of the most common CASp inspection failures
6

Website and Reservation System Non-Compliance

28 CFR §36.302(e) (ADA Reservation Rule)

Hotels must identify and describe accessible features on their reservation websites in sufficient detail for guests to independently assess whether rooms meet their needs. Accessible rooms must be bookable during the same hours and in the same manner as other rooms, held for disabled guests until all other rooms of that type are sold, and guaranteed when reserved. Potter Handy alone filed 565+ lawsuits targeting hotel reservation websites. The 2024 Marriott DOJ settlement expanded requirements to include OTA availability and loyalty-point bookability.

Regulatory Context

The DOJ's Reservation Rule (28 CFR §36.302(e)) requires hotels to: Allow guests with disabilities to reserve accessible rooms during the same hours and in the same manner as other guests Identify and describe accessible features in enough detail for independent assessment Hold accessible rooms for disabled guests until all other rooms of that type are sold Guarantee the specific accessible room reserved Make accessible rooms available on third-party OTAs (per 2024 Marriott settlement position) Allow booking of accessible rooms using loyalty program points (per 2024 Marriott settlement position)

$5,000–$25,000High — hundreds of cases annually; 2021 described as seeing a "dramatic increase in ADA hotel website lawsuits"
7

Communication Features Deficiency

ADA §809 / CBC 11B-806.3ADA §809; CBC 11B-806.3.

A percentage of guest rooms must include communication features for deaf or hard-of-hearing guests: visual alarms connected to the fire alarm system, visual notification devices for telephone calls and door knocks, TTY devices on request, and closed captioning on televisions. Hotels must also maintain a TTY at the front desk. Not more than 10% of mobility-accessible rooms can double as communication rooms.

Regulatory Context

Hotels must provide guest rooms with communication features (visual alarms, visual notification devices for telephone/door, TTY capability) per ADA §809 and CBC 11B-806.3. Not more than 10% of mobility-accessible rooms may simultaneously satisfy communication feature requirements. Hotels must also provide TTY devices at the front desk and on request for guest rooms, and staff must be trained in TTY operation.

$500–$3,000Moderate-High — specifically targeted in the 2021 DOJ 27-hotel Southern California enforcement action
8

Front Desk/Service Counter Height Non-Compliance

ADA §904.4 / CBC 11B-904.4

Hotel registration/service counters must have a portion no higher than 36 inches above finished floor with a clear floor space of 30" × 48" for wheelchair approach. Many older hotel front desks are built at 42"–44" heights with no lowered section.

Regulatory Context

Service counters must include an accessible portion no higher than 36 inches with 30" × 48" clear floor space. Many pre-ADA hotel front desks, typically 42"–44" high, require modification. The ADA-compliant range for work surfaces is 28–34 inches with a minimum 27" knee clearance.

$1,500–$5,000Moderate — included in CCDA top-10 as "Access Height of Goods, Support, Services, and Equipment" ranked #1 overall at 21%
Regulatory

Fitness Center Equipment Accessibility

Hotel fitness centers must have accessible routes to and throughout the space, accessible doors and operable controls, and at least one wheelchair-accessible piece of each type of exercise equipment (e.g., one accessible aerobic machine). Clear floor space adjacent to equipment must accommodate wheelchair users. Equipment controls must not require tight grasping or twisting.

Regulatory

Parking and Valet Accessibility

California's parking requirements exceed federal minimums: 2 accessible spaces per 25 total parking spaces (vs. federal 1 per 25), with 1 in 6 designated van-accessible. Hotels with valet service must provide accessible passenger loading zones adjacent to the entrance with a 60" minimum access aisle. Parking violations ranked #1 in CCDA complaints for the second half of 2024.

$4,000 (Cal. Civ. Code §52)

Unruh Civil Rights Act statutory minimum damages per violation

10,773,117 SF across ~20 professional office buildings

Century City office inventory (buildings >50K SF)

42 years (typical vintage ~late 1970s)

Average age of Century City office buildings (as of 2019)

~75–85%

Estimated share of commercial floor area built before 1990

88 identified buildings (LADBS 2018)

Non-ductile concrete buildings in Council District 5 (includes Century City)

A CASp (Certified Access Specialist) inspection provides the strongest available litigation shield under California law. Property owners who obtain a CASp inspection qualify for Qualified Defendant status under Cal. Civ. Code §55.51, which triggers a 90-day automatic court stay upon being sued, an early evaluation conference, and eligibility for a 75% reduction in statutory damages—from the $4,000 Unruh minimum down to $1,000 per violation under Cal. Civ. Code §55.56. This structured mitigation pathway converts ADA risk from an unpredictable liability into a manageable, documented compliance process.

Accessibility Demand

Who Needs Accessible Hotels in Century City

Century City's 10.8% disability rate and 13.4% senior population create high demand for accessible hotels.

10.8%

Residents with Disabilities

13.4%

Residents 65+

73,065

Veterans

Accessible accommodations serve traveling populations with disabilities and mobility needs.

Investment vs. Exposure

Cost vs. Risk for Hotels in Century City

With hotel ADA settlements in Century City ranging from $3K to $52K and 8 documented violation categories, a proactive CASp inspection is the most cost-effective protection.

A CASp inspection costs a fraction of a single ADA lawsuit settlement.

Inspection Cost

$2,500–$5,000

5-8 hours on-site

Typical Settlement

$3K–$52K

Based on Century City data

Protection Value

1:12

Return on compliance investment

Permit Requirements

Building Department & Permit Requirements

Los Angeles Department of Building and Safety (LADBS) in Century City oversees ADA compliance for 9 hotels — CBC Chapter 11B (California Building Standards Code); LADBS plan check applies 11B framework for commercial alterations.

Los Angeles Department of Building and Safety (LADBS)

City of Los Angeles jurisdiction — Century City is a neighborhood within LA, not an independent city. LADBS handles building permits and code plan review; LA Department of City Planning handles zoning/Specific Plan clearances.

Current accessibility codeCBC Chapter 11B (California Building Standards Code); LADBS plan check applies 11B framework for commercial alterations
Path-of-travel triggerCBC Section 11B-202.4 — alterations affecting an area of primary function trigger accessible path-of-travel upgrades (entrance, route, restrooms, parking)
See full details →

Local Resources

Local Programs & Resources

4 local programs

Safe Sidewalks LA Rebate Program

City of Los Angeles program offering rebates for sidewalk repairs, including accessibility-related work. Subject to funding limits and waitlist-style constraints—private projects should not rely on rebates to offset right-of-way accessibility costs without confirming current availability.

LA County Small Business Mobility Fund

Los Angeles County Department of Economic Opportunity program supporting improvements that may include accessibility and mobility-related upgrades for small businesses. Subject to eligibility requirements and funding rounds.

View all programs for Century City
CASp

License #991

State-Certified Accessibility Specialist

MS

Built Ronald Reagan UCLA Medical Center

MS Structural Engineering · Tutor Perini

QD

Qualified Defendant Status

Reduces statutory damages 75% with 90-day litigation stay

JR

Jose Rubio

Certified Access Specialist

CASp #991
Built Ronald Reagan UCLA Medical CenterMS Structural EngineeringTutor Perini veteran$1M+ insured

Jose Rubio brings over 15 years of structural engineering and construction experience to every CASp inspection. He built Ronald Reagan UCLA Medical Center with Tutor Perini and holds an MS in Structural Engineering.

View full credentials →
The information on this site is for general informational purposes only and does not constitute legal advice. Consult a licensed attorney for advice specific to your situation.

Frequently Asked Questions

Protect Your Century City Hotel

Schedule a CASp inspection and activate Qualified Defendant status under California Civil Code §55.56.

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