Zachary Morris v. Waukesha Hospitality, LLC

Case Summary

According to the complaint, plaintiff Zachary Morris, a visually-impaired individual, is suing Waukesha Hospitality, LLC for failing to make its website, www.theinglesidehotel.com, accessible under the Americans with Disabilities Act (ADA). Morris alleges that he encountered multiple barriers while attempting to book a hotel room, which prevented him from accessing the services offered on the website. The complaint cites specific access issues, including missing alt-text and broken links, which hinder the usability of the site for blind users. Morris seeks a permanent injunction requiring the defendant to comply with accessibility standards and to ensure that the website is usable by individuals with disabilities.

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 that denied him full access to the website.
• Defendant failed to comply with WCAG 2.1 guidelines.

Requested Relief

• A preliminary and permanent injunction to prohibit Defendant from violating the ADA.
• An order requiring Defendant to make its website fully compliant with the ADA.
• Payment of nominal damages.
• An award of costs and expenses of this action together with reasonable attorneys’ and expert fees.

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