Constance Henry v. Carnivore Snax, LLC

Case Summary

According to the complaint, Constance Henry, a visually impaired individual, is suing Carnivore Snax, LLC for failing to make their website, Carnivoresnax.com, accessible to blind users. The plaintiff alleges that the website contains significant barriers that prevent visually impaired individuals from completing transactions, violating the Americans with Disabilities Act (ADA). The complaint details specific accessibility issues encountered by the plaintiff, including lack of alt-text for images and reliance on mouse navigation. The plaintiff seeks a permanent injunction to require the defendant to make the website accessible and compensatory damages for the class members affected by these barriers.

Causes of Action

• Violation of the Americans with Disabilities Act (ADA)
• Declaratory Relief

Key Allegations

• Defendant's website is inaccessible to visually impaired individuals.
• Plaintiff was denied the ability to complete a purchase due to accessibility barriers.
• Defendant failed to implement necessary modifications to make the website accessible.

Requested Relief

• Permanent injunction to make the website accessible
• Compensatory damages for class members
• Certification of the case as a class action

Proposed Class

All legally blind individuals in the United States who have attempted to access Carnivoresnax.com and as a result have been denied access to the enjoyment of goods and services offered by Carnivoresnax.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).