Muhammad v. Barings LLC
Filed
Case details
- Defendant’s website
Summary
On December 20, 2019, Rasul Muhammad filed a Complaint in Illinois Federal court against Barings LLC BBC PH Kinzie LLC. Plaintiff Rasul Muhammad alleges that www.kinziehotel.com is not accessible per the WCAG 2.1 accessibility standard(s).
About the defendant
Barings LLC owns and operates the Kinzie Hotel in downtown Chicago.
What the complaint says
The problems the plaintiff describes with the website.
- Many features on the Website lacks alt. text, which is the invisible code embedded beneath a graphical image.
- Many features on the Website also fail to add a label element or title attribute for each field.
- The Website also contained a host of broken links, which is a hyperlink to a nonexistent or empty webpage.
Legal claims
The laws the plaintiff says the defendant broke, called causes of action.
- Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
- Declaratory Relief
What the plaintiff asks for
What the plaintiff wants the court to order.
- A Declaratory Judgment that at the commencement of this action BARINGS was in violation of the specific requirements of Title III of the ADA described above, and the relevant implementing regulations of the ADA, in that BARINGS took no action that was reasonably calculated to ensure that its Website is fully accessible to, and independentlyusable by, individuals with visual disabilities;
- A permanent injunction pursuant to 42 U.S.C. § 12188(a)(2) and 28 CFR § 36.504(a) which directs Defendant to take all steps necessary to bring its Website into full compliance withthe requirements set forth in the ADA, and its implementing regulations, so that its Website is fully accessible to, and independently usable by, blind individuals, and which furtherdirects that the Court shall retain jurisdiction for a period to be determined to ensure that Defendant has adopted and is following an institutional policy that will in fact cause it toremain fully in compliance with the law—the specific injunctive relief requested by Plaintiff is described more fully in paragraph 8 above;
- An award of costs and expenses of this action;
- Payment of reasonable attorneys’ fees, pursuant to 42 U.S.C. § 12205 and 28 CFR § 36.505, including costs of monitoring Defendant’s compliance with the judgment;
- An order certifying the Class under Fed. R. Civ. P. 23(a) & (b)(2) and/or (b)(3), appointing Plaintiff as Class Representative, and his attorneys as Class Counsel; and
- Such other and further relief as this Court deems just and proper.