What was Robles v. Domino’s Pizza?

Published July 10, 2024

After six years of litigation and appeals, the case of Robles v. Domino’s Pizza LLC finally reached a resolution in June 2022. Initially filed in 2016, the case would find its way through district courts, the Ninth Circuit Court of Appeals, and even the United States Supreme Court (SCOTUS). 

The case is considered by many to be a landmark for accessibility litigation. Its consequences and implications can be seen throughout the world of accessibility, business, and tech. 

In this piece, we will discuss the details of Robles v. Domino’s and provide some insight into its significance.

Background

In 2016, Guillermo Robles, a Californian with visual impairments, filed suit for damages against Domino’s Pizza. The plaintiff claimed that neither Domino’s website nor its app was compatible with his screen reader. According to a report by CNBC, Robles allegedly ran into difficulties at least twice before deciding to file suit.

Robles claimed that because he could not use his assistive device to order, Domino’s violated Title III of the Americans with Disabilities Act (ADA). Title III forbids the discrimination of individuals in places of public accommodation, the definition of which includes any physical location of business. Robles and his attorneys maintained that a business’ website is under the same obligations as any of its physical locations. 

Since this incompatibility with assistive technology prevented Robles from accessing the same services that a sighted person might use, he was essentially excluded because of his disability. As such, Domino’s violated the ADA.

Domino’s argued that Title III of the ADA did not apply to their online or digital services. They also argued that any attempt to apply the ADA’s regulations to its site would violate the pizza chain’s due process rights. This is because, at the time, The Department of Justice (DOJ) had not published any actionable guidance to adhere to accessibility standards. 

Furthermore, Domino’s offered alternatives to online ordering at the time. These included a 24/7 hotline, voice ordering enabled for devices like Alexa and Google Home, and Dom, their appropriately-named, proprietary voice ordering assistant. However, according to Equidox, “the plaintiff did not consider those features to be equal to online access.” 

Initial trial

Despite agreeing with Robles that websites should be considered places of public utility, the judge who initially saw the case ended up throwing it out. According to Equidox, this is “because the Department of Justice never created specific guidelines as to how businesses should comply with Title III.” As such, pursuing these charges would be a violation of Domino’s’ due process rights.

Robles appeals

Following the initial dismissal of the case, Robles and his team filed an appeal with the Ninth Circuit Court of Appeals. They asked the court to evaluate whether the ADA should apply to Domino’s website and whether the application of the ADA would infringe on Domino’s due process rights. 

After deliberating on the appeal, the Ninth Circuit Court n ruled that the ADA should apply to Domino’s online platforms. On page 13 of their decision, they determined that Domino’s website and app, “connect customers to the goods and services of Domino’s physical restaurants.”

Furthermore, they determined that the application of ADA policies did not violate Domino’s right to due process. On page 21 of their decision, they reasoned that “Domino’s has received fair notice that its website and app must provide effective communication and facilitate ‘full and equal enjoyment’ … to its customers who are disabled.” 

The Circuit court went on to say, “Our Constitution does not require that Congress or DOJ spell out exactly how Domino’s should fulfill this obligation.”

As such, the case was remanded back to the district court. 

Domino’s appeals

Before the case went back to trial, Domino’s appealed to the United States Supreme Court and petitioned what’s called a Writ of Certiorari. In other words, they sent a request to SCOTUS to then request the case files from the district court so that they might review them. 

SCOTUS denied Domino’s petition but did not express a reason why. Motivation aside, the denial spoke volumes. Not only did it imply SCOTUS’ concurrence with the 9th Circuit Court, but it also set an accessibility precedent that continues to have an impact.  Namely, it determined that websites are places of public accommodation. 

Upheld remand and eventual settlement

With their request denied and the 9th Circuit’s ruling upheld, Domino’s was forced to battle out the case in court. The case would last another two and a half years.

On June 23, 2021, five years after Robles first filed suit, the judge ruled that Domino’s had violated Title III of the ADA. This came after the court granted Robles’ motion for summary judgment. 

In the context of a lawsuit, a motion for summary judgment is a request made by one party to have the court rule in their favor without a trial. The logic is that there is enough evidence to support the party’s case that a trial isn’t necessary. 

In the case of Robles, his team reasoned that the evidence of Domino’s inaccessibility was so obvious that the judge ought to be able to rule in their favor based solely on that evidence.

The court granted Robles’ motion on June 23, 2021.

Finally, in June 2022, Domino’s Pizza settled with Guillermo Robles. The terms of this settlement have not been released to the public at the time of writing.

Lasting effects

Robles v. Domino’s Pizza proved to be an incredibly important case in accessibility law. Here are some of the more important takeaways:

  • Website obligation –For one thing, it cleared up any misunderstanding around the accessibility obligations of websites. Any online platform used by a business is considered a place of public accommodation. Thus, exclusion from these platforms based on disability is considered a violation of the ADA.

  • Accessibility advocacy – The Robles v. Domino’s case has also given hope to people with disabilities who want to advocate for themselves. Robles’ victory in court showed that fighting for accessibility can yield fruitful results. 

  • Increased lawsuits – The establishment of websites as places of public accommodation has reset the stage in accessibility litigation. The precedent set by Robles v. Domino’s means that businesses are now responsible for making their online platforms accessible. The steady rise of digital accessibility lawsuits in the US shows that law firms have taken the offensive in this matter.

Conclusion

Given its recent resolution, we have yet to see the full extent of the impact of Robles v. Domino’s 'Pizza. We can say, for sure, that it will be remembered as a pivotal moment in the history of digital accessibility.

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