Erika Randolph v. Bradshaw Taylor USA Inc.

Case Summary

According to the complaint, Erika Randolph, a visually-impaired individual, is suing Bradshaw Taylor USA Inc. for failing to make their website, Sherpaadventuregear.com, accessible to blind users, violating the Americans with Disabilities Act (ADA). Randolph alleges that the website contains significant barriers that prevent blind individuals from completing transactions independently. She seeks a permanent injunction to require the defendant to make the website accessible and compensatory damages for the discrimination faced. The complaint highlights various accessibility issues, including improper navigation and lack of necessary features for screen-reader users.

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 her from completing a purchase.
• Defendant has failed to take necessary steps to make the website accessible.

Requested Relief

• Preliminary and permanent injunction to prohibit violations of the ADA
• Injunction requiring compliance with the ADA
• Declaration of discrimination against the blind
• Class action certification
• Payment of nominal damages
• Pre- and post-judgment interest
• Award of costs and expenses
• Punitive damages
• Compensatory damages

Proposed Class

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