Constance Henry v. Z Supply, LLC

Case Summary

According to the complaint, Constance Henry, a visually impaired individual, is suing Z Supply, LLC for failing to make its website, https://zsupplyclothing.com, accessible to blind users, violating the Americans with Disabilities Act (ADA). Henry alleges that the website contains numerous barriers that prevent her and others from independently navigating and completing purchases. These barriers include a lack of alternative text for images, reliance on mouse navigation, and inadequate labeling of interactive elements. Henry seeks a permanent injunction to require Z Supply to make its website accessible and compensatory damages for the discrimination faced. The case is filed as a class action on behalf of all legally blind individuals who have been denied access to the website.

Causes of Action

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

Key Allegations

• Website is inaccessible to visually impaired individuals
• Significant access barriers prevent blind users from completing transactions
• Failure to provide alternative text for images
• Website requires mouse usage, excluding keyboard navigation

Requested Relief

• Preliminary and permanent injunction to prohibit violations of the ADA
• Injunction requiring compliance with ADA standards
• Declaration of discrimination against visually impaired individuals
• Class action certification
• Pre- and post-judgment interest
• Award of costs and attorney fees

Proposed Class

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

Jurisdiction & Venue

Subject-matter jurisdiction under 28 U.S.C. § 1331 and 42 U.S.C. § 12182; venue proper under 28 U.S.C. §1391(b)(1) and (2)