Rosemarie Ramirez v. B.a.f.s., Inc.

Summary

According to the complaint, plaintiff ROSEMARIE RAMIREZ, a visually-impaired individual, is suing B.A.F.S., INC. for failing to make its website, www.themillstores.com, accessible under the Americans with Disabilities Act (ADA). The plaintiff alleges that she encountered multiple barriers while attempting to purchase a dog toy, which prevented her from accessing the website's goods and services. The complaint cites specific access issues such as missing alt-text and broken links that hinder the use of screen-reading software. The plaintiff seeks a permanent injunction to require the defendant to make its website compliant with accessibility standards and to implement policies ensuring ongoing accessibility.

About the defendant

Offers a variety of pet products including dog toys, training aids, and related accessories for online sale.

What the complaint says

The problems the plaintiff describes with the website.

• Defendant's website is not accessible to blind and visually impaired individuals.
• Plaintiff encountered barriers preventing her from completing a purchase on the website.
• Defendant has failed to comply with WCAG 2.1 guidelines.

Legal claims

The laws the plaintiff says the defendant broke, called causes of action.

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

What the plaintiff asks for

What the plaintiff wants the court to order.

• Permanent injunction requiring Defendant to make its website accessible.
• Declaration that Defendant’s website discriminates against blind individuals.
• Certification of the Class.

Proposed class

The group of people the plaintiff asks to represent, so the case can cover them too.

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.