Tanisia Bowman v. KIYONNA CLOTHING, INC.

Case Summary

According to the complaint, plaintiff Tanisia Bowman, a legally blind individual, is suing Kiyonna Clothing, Inc. for failing to make their website, Kiyonna.com, accessible to blind users. The complaint alleges that the website contains significant barriers that prevent blind individuals from completing transactions independently, violating the Americans with Disabilities Act (ADA). Bowman claims that despite her attempts to purchase a dress, she faced numerous accessibility issues, including inadequate alt-text and mouse-dependency, which hindered her ability to navigate the site. The plaintiffs seek a permanent injunction to require Kiyonna Clothing to make their website accessible and compensatory damages for the discrimination experienced.

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

• Kiyonna.com is inaccessible to blind and visually-impaired persons
• Defendant failed to design and maintain an accessible website
• Plaintiff encountered significant access barriers preventing online transactions

Requested Relief

• Preliminary and permanent injunction to prohibit violations of the ADA
• Injunction requiring compliance with ADA standards
• Declaration of discrimination against the blind
• Class action certification
• Payment of nominal damages
• Pre- and post-judgment interest
• Award of costs and expenses
• Punitive damages
• Compensatory damages

Proposed Class

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