Erika Randolph v. Rockmount Ranch Wear Mfg. Co.

Case Summary

According to the complaint, Erika Randolph, a visually-impaired individual, is suing Rockmount Ranch Wear Mfg. Co. for failing to make its website, Rockmount.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 independently navigating and completing purchases. The complaint seeks a permanent injunction to require the defendant to make the website accessible, along with compensatory damages for the discrimination faced by Randolph and other class members. The plaintiff's counsel argues that the website's design relies on visual elements that are not compatible with screen-reading software, which is essential for blind users to access online content.

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 make reasonable modifications to its website to ensure accessibility

Requested Relief

• A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act
• A preliminary and permanent injunction requiring Defendant to make its website fully compliant with the ADA
• A declaration that Defendant's website discriminates against the blind
• An order certifying this case as a class action
• Payment of nominal damages
• Pre- and post-judgment interest
• An award of costs and expenses of this action together with reasonable attorneys’ and expert fees
• Punitive damages
• Compensatory damages in an amount to be determined at trial

Proposed Class

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