LUCIUS v. SUPER LIQUORS HOLDING, LLC

• numerous portions of the website do not interface with and are not readable by SRS.
• there are two large sale images on the Specials page. Both images are missing labels, so screen reader users only hear the Specials header, the two sale images are not announced.
• None of the required fields in the Contact Us form are announced as such. Screen reader users only know which fields are required after they submit the form and receive an error message.
• The Tasting control icons are actionable elements, but they are not in the tab index, so they are skipped when navigating with the Tab key.
• Skip navigation is not available.
• The "View as" elements do not have labels and it may be unclear what they are for.
• An interstitial is displayed when a user first visits this website. This is essentially a full-page pop-up that covers the homepage and requires a user to make a selection before using the website. In this case, a user must confirm that they are over 21, however, focus does not move into the interstitial nor is it announced when it is displayed. This makes the website virtually unusable for persons who are blind.
• The text content for the two promo images on the Specials page is not announced to screen reader users. This is in addition to images not being labeled. The content in the images are also not navigable nor are they announced so screen reader users are not aware of these specials.

VIOLATION OF TITLE III OF THE AMERICANS WITH DISABILITIES ACT

• The Court issue a declaratory judgment that determines that the defendant's website at the commencement of the subject lawsuit is in violation of Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
• the court issue a declaratory judgment that determines that the defendant's website is in violation of Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
• The Court issue a Declaratory Judgment that Defendant has violated the ADA by failing to monitor and maintain its website to ensure that it is readily accessible to and usable by persons with vision impairment
• That this Court issue an Order directing Defendant to alter its website to make it accessible to, and useable by, individuals with disabilities to the full extent required by Title III of the ADA
• That this Court enter an Order directing Defendant to evaluate and neutralize its policies and procedures towards persons with disabilities for such reasonable time so as to allow Defendant to undertake and complete corrective procedures
• That this Court enter an Order directing Defendant to continually update and maintain its website to ensure that it remains fully accessible to and usable by visually impaired individuals
• An award of attorney’s fees, costs and litigation expenses pursuant to 42 U.S.C. § 12205
• Such other relief as the Court deems just and proper, and/or is allowable under Title III of the Americans with Disabilities Act.