Erika Randolph v. Kitchen Resource Direct LLC

Case Summary

According to the complaint, Erika Randolph, a visually-impaired individual, is suing Kitchen Resource Direct LLC for failing to make its website, Cabinets.com, accessible to blind users. Randolph alleges that the website contains significant barriers that prevent her and others with visual impairments from independently accessing and purchasing products. The complaint cites violations of the Americans with Disabilities Act (ADA) and seeks a permanent injunction to require the defendant to make necessary changes to its website, along with compensatory damages for the discrimination faced by Randolph and the class members.

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 its website accessible.

Requested Relief

• A preliminary and permanent injunction to prohibit Defendant from violating the ADA
• An order requiring Defendant to make its website compliant with the ADA
• Payment of nominal damages
• Compensatory damages
• Punitive damages
• An award of costs and expenses of this action together with reasonable attorneys’ and expert fees

Proposed Class

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