Erika Randolph v. Livegood Supplements Inc

Case Summary

According to the complaint, Erika Randolph, a visually-impaired individual, is suing Livegood Supplements Inc for failing to make their website, Livegood.com, accessible to blind users. The complaint alleges that significant barriers prevent blind individuals from independently navigating the site and completing purchases, violating the Americans with Disabilities Act (ADA). Randolph seeks a permanent injunction to require Livegood to make its website accessible and compensatory damages for the discrimination faced. The complaint highlights various access barriers, including ambiguous link texts and the requirement of mouse usage, which hinder blind users from accessing the website's services.

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

• Livegood.com is inaccessible to blind and visually-impaired persons due to significant access barriers.
• Plaintiff was denied the ability to independently navigate and complete a purchase on Livegood.com.
• Defendant failed to implement basic accessibility features required for blind users.

Requested Relief

• A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act.
• A declaration that Defendant discriminates against the blind and fails to provide access as required by the ADA.
• 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 Livegood.com and as a result have been denied access to the enjoyment of goods and services offered by Livegood.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).