An Illinois federal court recently dismissed a slip-and-fall plaintiff’s negligence claims against Hilton Worldwide that stemmed from a fall at a Nebraska Hampton Inn. Roeber v. Hilton Worldwide Holdings., Inc., 2026 WL 891865 (N.D. Ill. Mar. 31, 2026).
While traveling through Nebraska, Gary Roeber and his wife, both of whom were Illinois residents, used the Hilton app to book a room at a Hampton Inn property in North Platte, Nebraska (the Hotel). During his stay, Roeber slipped and fell on a walkway at the Hotel, fracturing his hip. Roeber sued the Hotel’s owner and property manager in Illinois federal court. Roeber also sued the owner of the Hampton Inn brand—Hilton Worldwide—asserting that Hilton Worldwide’s negligence contributed to his fall and injuries. Roeber acknowledged Hilton Worldwide’s subsidiaries in his complaint, including the licensing entity of the Hampton Inn brand. But Roeber did not sue the licensing entity or any other subsidiaries. Hilton Worldwide moved to dismiss Roeber’s claims for lack of personal jurisdiction.
The court granted Hilton Worldwide’s motion, reasoning that Roeber failed to show that an Illinois court could exercise personal jurisdiction over Hilton Worldwide. The court first found that Roeber failed to establish that the court had general jurisdiction over Hilton Worldwide, reasoning that Hilton Worldwide had no employees or properties in Illinois or significant involvement with the Hotel and Roeber failed to otherwise show that Hilton Worldwide was “at home” in Illinois. The court next found that Roeber failed to show that (i) Hilton Worldwide personally availed itself of doing business in Illinois and (ii) Roeber’s injuries arose out of Hilton Worldwide’s actions in Illinois, and therefore, failed to establish the court could exercise specific jurisdiction over Hilton Worldwide. Roeber first asserted that Hilton purposefully availed itself of doing business in Illinois by advertising extensively to Illinois residents through its interactive booking website. The court, however, noted that national advertising on a booking website does not, alone, show that Hilton Worldwide availed itself of the privilege of conducting business in Illinois. Roeber next asserted that, because he booked the Hotel through Hilton’s app, his injuries necessarily arose out of Hilton Worldwide’s actions in Illinois. Again, the court disagreed, noting that it was unclear whether Roeber booked the Hotel in Illinois, and the mere fact that Roeber was an Illinois resident was irrelevant for establishing personal jurisdiction over Hilton Worldwide.