Timothy Hernandez v. CZS GROUP, LLC

Case Summary

According to the complaint, Timothy Hernandez, a visually impaired individual, is suing CZS Group, LLC for failing to make its website, www.teriyakeone.com, accessible to blind users. The complaint alleges that the website contains numerous barriers that prevent blind individuals from fully accessing its services, including missing alt-text and poorly labeled interactive elements. Hernandez claims that these barriers violate the Americans with Disabilities Act (ADA) and New York City Human Rights Law (NYCHRL). He seeks a permanent injunction to require the defendant to make the website accessible and compensatory damages for the discrimination faced. The complaint highlights the need for compliance with WCAG 2.1 guidelines to ensure equal access for visually impaired consumers.

Causes of Action

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

Key Allegations

• Defendant's website is not accessible to blind and visually impaired individuals.
• Plaintiff encountered multiple access barriers while attempting to use the website.
• Defendant has failed to comply with WCAG 2.1 guidelines.

Requested Relief

• Permanent injunction requiring Defendant to make its website accessible to blind individuals.
• Compensatory damages for violations of civil rights under New York City Human Rights Law.
• Certification of the Class and Sub-Classes.

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, and venue is proper under 28 U.S.C. §1391(b)(1) and (2).