Sumaya Hussein v. Raw Elements CA LLC

Case Summary

According to the complaint, Sumaya Hussein, a visually impaired individual, is suing Raw Elements CA LLC for failing to make its website accessible to blind users, violating the Americans with Disabilities Act (ADA). Hussein alleges that the website contains significant barriers that prevent her and others from independently navigating and completing purchases. The complaint cites specific issues such as lack of alternative text for images and reliance on mouse navigation, which excludes visually impaired users. Hussein seeks a permanent injunction to require the defendant to make the website accessible and compensatory damages for the discrimination faced. The case is filed as a class action on behalf of all legally blind individuals in the U.S. who have faced similar barriers.

Causes of Action

• Violation of the Americans with Disabilities Act (ADA)
• Declaratory Relief

Key Allegations

• Website is inaccessible to visually impaired individuals
• Access barriers prevent independent navigation and purchases
• Defendant failed to provide necessary accommodations for screen-reader users

Requested Relief

• Preliminary and permanent injunction to prohibit violations of the ADA
• Injunction requiring compliance with ADA
• Declaration of discriminatory practices
• Class action certification
• Pre- and post-judgment interest
• Award of costs and attorney fees

Proposed Class

all legally blind individuals in the United States who have attempted to access the Website and as a result have been denied access to the enjoyment of goods and services offered by the Website, during the relevant statutory period.

Jurisdiction & Venue

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)