Randolph Simmons v. World Market, LLC, Cost Plus World Market, LLC

Case Summary

According to the complaint, Randolph Simmons, a legally blind individual, is suing World Market, LLC and Cost Plus World Market, LLC for violations of the Americans with Disabilities Act due to their ecommerce website, www.worldmarket.com, being inaccessible to blind users. Mr. Simmons alleges that he encountered numerous accessibility barriers while attempting to purchase specific furniture items, which prevented him from accessing essential product information. The complaint cites various accessibility failures, including missing alternative text and broken ARIA attributes. Mr. Simmons seeks injunctive relief to require the defendants to make their website compliant with accessibility standards and to ensure ongoing accessibility for blind consumers.

Causes of Action

• Violations of the ADA
• Violations of the New York State Human Rights Law
• Violation of the New York State Civil Rights Law
• Violations of the New York City Human Rights Law
• Declaratory Relief

Key Allegations

• Plaintiff encountered pervasive accessibility barriers that prevented him from independently accessing product descriptions, materials information, pricing, dimensions, assembly requirements, and customer reviews.
• Accessibility barriers included missing alternative text, empty buttons, empty links, broken ARIA attributes, missing form labels, contrast failures, and inaccessible dynamic regions.
• Defendants have failed to remediate the barriers identified in this action despite longstanding federal guidance and the availability of automated testing tools.

Requested Relief

• A preliminary and permanent injunction prohibiting Defendant from violating the ADA and the laws of New York
• A preliminary and permanent injunction requiring Defendant to take all steps necessary to make the Website fully compliant with the ADA
• A declaration that Defendant owns, maintains, and/or operates the Website in a manner that discriminates against the blind
• An order certifying the Class and Sub-Classes under Fed. R. Civ. P. 23
• Compensatory damages in an amount to be determined by proof
• Pre-judgment and post-judgment interest
• 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 www.worldmarket.com and were denied equal access to its digital content, product information, and online purchasing functions due to persistent accessibility barriers during the relevant statutory period.

Jurisdiction & Venue

This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § 1331 and 42 U.S.C. § 12188, as Plaintiff alleges violations of Title III of the Americans with Disabilities Act.