National Federation of the Blind v. Target Corp.
2006 U.S. Dist. LEXIS 63591, 452 F. Supp. 2d 946, 18 Am. Disabilities Cas. (BNA) 1148 (2006)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under Title III of the Americans with Disabilities Act (ADA), the inaccessibility of a commercial website can constitute discrimination if it impedes the full and equal enjoyment of the goods and services offered at a physical place of public accommodation. To state a claim, a plaintiff must allege a sufficient 'nexus' between the website's services and the physical retail space.
Facts:
- Target Corporation operates approximately 1,400 physical retail stores nationwide.
- Target also owns and operates Target.com, a commercial website.
- Through Target.com, customers can purchase many of the same items available in Target's physical stores.
- Target.com also allows customers to perform functions related to the physical stores, including accessing store location information, refilling prescriptions for in-store pickup, and printing coupons for in-store redemption.
- The National Federation of the Blind and Bruce Sexton, who are blind, alleged that Target.com is inaccessible to them.
- They claimed the website lacks features like 'alternative text' for images, which is necessary for screen-reading software used by blind individuals to interpret and vocalize web content.
- The plaintiffs alleged this inaccessibility denies them equal access to the goods, services, and benefits offered in Target's physical stores.
Procedural Posture:
- National Federation of the Blind and other plaintiffs filed a lawsuit against Target Corporation in the Superior Court of California for the County of Alameda, a state trial court.
- Target removed the case to the U.S. District Court for the Northern District of California, a federal trial court.
- Target filed a motion to dismiss the complaint for failure to state a claim under Rule 12(b)(6).
- The plaintiffs filed a motion for a preliminary injunction to compel Target to make its website accessible.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the operation of a commercial website that is inaccessible to the blind violate the Americans with Disabilities Act (ADA) and related state laws when that website is heavily integrated with and acts as a gateway to the owner's physical retail stores?
Opinions:
Majority - Patel, District Judge
Yes. The operation of an inaccessible commercial website can violate the ADA when a sufficient nexus exists between the website and the goods and services of a physical place of public accommodation. While the Ninth Circuit holds that a 'place of public accommodation' under the ADA must be a physical space, the statute's protections extend to the services of that place, not merely services provided in that place. The court rejected Target's argument that the ADA is implicated only when there is a denial of physical access to a store, noting the statute aims for 'full and equal enjoyment' of all goods and services. Here, the plaintiffs sufficiently alleged a nexus because Target.com is 'heavily integrated with the brick-and-mortar stores and operates in many ways as a gateway to the stores.' Therefore, to the extent the website's inaccessibility impedes enjoyment of the stores' offerings, the plaintiffs have stated a valid claim. The court also denied dismissal of the state law claims, as a violation of the ADA constitutes a violation of California's Unruh Act and Disabled Persons Act. Finally, the court found Target's dormant Commerce Clause challenge to be premature, as it is not yet clear what the practical effect of applying California's laws would be.
Analysis:
This decision was a landmark ruling in the early stages of internet law, establishing that the ADA's accessibility requirements could extend to the digital realm of commercial websites. By embracing the 'nexus' theory, the court provided a pathway for applying disability rights laws to websites connected to physical businesses, even in jurisdictions that define 'public accommodation' strictly as a physical place. This case significantly broadened the scope of corporate liability under the ADA and spurred a wave of litigation and corporate awareness regarding web accessibility, shaping legal standards for online businesses for years to come.
