Castillo v. Jo-Ann Stores, LLC
286 F. Supp. 3d 870 (2018)
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Rule of Law:
Under Title III of the Americans with Disabilities Act (ADA), a retailer's website that is inaccessible to a visually impaired individual can be the basis for a discrimination claim if a sufficient nexus exists between the website and the retailer's physical stores, such that the website's inaccessibility impedes the full and equal enjoyment of the goods and services offered in those stores.
Facts:
- Rebecca Castillo is a blind and visually impaired individual who relies on screen-reading software to access website content.
- Jo-Ann Stores, LLC is a specialty retailer that operates physical 'brick-and-mortar' stores as well as a commercial website, www.joann.com.
- Jo-Ann's website provides services connected to its physical stores, including a store locator feature, information about in-store sales and discounts, and the ability to browse products.
- Castillo attempted to use www.joann.com with her screen-reading software but was unsuccessful.
- The website's design was not compatible with her software, preventing her from locating physical stores, learning about sales, browsing products, or completing transactions.
- Castillo alleged that these access barriers on the website deterred her from visiting Jo-Ann's physical store locations.
Procedural Posture:
- Plaintiff Rebecca Castillo filed a complaint against Defendant Jo-Ann Stores, LLC in the U.S. District Court for the Northern District of Ohio.
- The complaint alleged violations of Title III of the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act.
- Defendant Jo-Ann filed a Motion to Dismiss the complaint for failure to state a claim upon which relief can be granted pursuant to Federal Rule of Civil Procedure 12(b)(6).
- The case came before the Magistrate Judge for a ruling on the Defendant's Motion to Dismiss.
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Issue:
Does a complaint state a plausible claim for relief under Title III of the ADA where it alleges that a retailer's website is inaccessible to a visually impaired person, thereby creating a barrier to enjoying the goods and services of the retailer's physical stores?
Opinions:
Majority - Kathleen B. Burke
Yes. A complaint states a plausible claim for relief under Title III of the ADA when it sufficiently alleges a nexus between an inaccessible website and a retailer's physical places of public accommodation. The court determined that while Sixth Circuit precedent holds that a 'place of public accommodation' must be a physical place, that precedent explicitly left open the question of whether a plaintiff must physically enter the accommodation to bring a claim. Here, Castillo is not required to show she was physically denied entry to a store; rather, she must show that the inaccessible website acted as a barrier to her 'full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations' of the physical stores. The complaint successfully established this nexus by alleging that the website's inaccessible features, such as the store locator and information about in-store sales, prevented her from effectively accessing the benefits of the brick-and-mortar stores. The court rejected Jo-Ann's argument that a lack of specific government regulations on website accessibility creates a due process violation, reasoning that the ADA's general non-discrimination requirement provides sufficient notice and the specifics of compliance are a matter of remedy, not liability.
Analysis:
This decision contributes to the developing jurisprudence on the application of the ADA to websites, particularly in jurisdictions that have adopted the 'nexus' approach. By distinguishing prior circuit precedent, the court clarified that the requirement for a 'physical place' does not foreclose claims based on intangible barriers, like an inaccessible website, as long as those barriers connect to and impede access to the physical place. This ruling reinforces that businesses with both a physical and online presence must ensure their digital platforms do not discriminate by preventing disabled customers from enjoying the benefits of their physical locations. It lowers the barrier for plaintiffs, who need only allege a plausible connection between the website and the store, rather than proving the website itself is a 'place of public accommodation.'
