Andre Battle v. M. Leonard International, Inc.

Case Summary

According to the complaint, Andre Battle, a visually-impaired individual, is suing M. Leonard International, Inc. for failing to make their website, Sanita.com, accessible to blind users, violating the Americans with Disabilities Act (ADA). Battle alleges that he encountered numerous barriers while attempting to purchase clogs online, including inaccessible navigation and lack of alternative text for images. He seeks a permanent injunction to require the defendant to make the website accessible and compensatory damages for the discrimination faced. The complaint also seeks class action status for all legally blind individuals who have faced similar issues with the website.

Causes of Action

• Violation of 42 U.S.C. §§ 12181 et seq. - Title III of the Americans with Disabilities Act
• Declaratory Relief
• Negligent Infliction of Emotional Distress

Key Allegations

• Defendant's website is not accessible to blind and visually-impaired persons.
• Plaintiff encountered multiple accessibility barriers preventing him from completing a purchase on Sanita.com.
• Defendant has failed to take necessary steps to make its website accessible.

Requested Relief

• A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act.
• A declaration that Defendant's website discriminates against the blind.
• Payment of nominal damages.
• Compensatory damages in an amount to be determined at trial.
• Punitive damages.

Proposed Class

all legally blind individuals in the United States who have attempted to access Sanita.com and as a result have been denied access to the enjoyment of goods and services offered by Sanita.com, during the relevant statutory period.

Jurisdiction & Venue

This Court has subject-matter jurisdiction under 28 U.S.C. § 1331 and 42 U.S.C. § 12182; venue is proper under 28 U.S.C. §1391(b)(1) and (2).