Rosemarie Ramirez v. B.a.f.s., Inc.

Case Summary

According to the complaint, plaintiff ROSEMARIE RAMIREZ, a visually-impaired individual, is suing B.A.F.S., INC. for failing to make its website, www.themillstores.com, accessible under the Americans with Disabilities Act (ADA). The plaintiff alleges that she encountered multiple barriers while attempting to purchase a dog toy, which prevented her from accessing the website's goods and services. The complaint cites specific access issues such as missing alt-text and broken links that hinder the use of screen-reading software. The plaintiff seeks a permanent injunction to require the defendant to make its website compliant with accessibility standards and to implement policies ensuring ongoing accessibility.

Causes of Action

• Violations of the ADA, 42 U.S.C. § 12182 et seq.
• Declaratory Relief

Key Allegations

• Defendant's website is not accessible to blind and visually impaired individuals.
• Plaintiff encountered barriers preventing her from completing a purchase on the website.
• Defendant has failed to comply with WCAG 2.1 guidelines.

Requested Relief

• Permanent injunction requiring Defendant to make its website accessible.
• Declaration that Defendant's website discriminates against blind individuals.
• Certification of the Class.

Proposed Class

All legally blind individuals in the United States who have attempted to access Defendant’s Website and as a result have been denied access to the equal enjoyment of goods and services, 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.