Website Accessibility at the Forefront of New York Courts


Young v. Metro Learning Inst. Inc. is a case about a visually impaired plaintiff who could not get information about classes offered on the defendant's website, claiming a violation of Title III of the ADA. The defendant claimed that the plaintiff was not a plausible student because most of their classes were for non-English speakers and/or require visual acuity. However, the court denied the defendant's motion to dismiss for lack of personal jurisdiction and 12(b)(6) motion, allowing the defendant to take jurisdictional discovery on the issue of whether the plaintiff has Article III standing.

The court found that a plaintiff need not provide detailed factual allegations to survive a motion to dismiss and that the defendant's allegation that the plaintiff did not fit the demographic of students that would plausibly enroll was not sufficient. The court also clarified that claims under the Rehabilitation Act and the NYSHRL are subject to the same legal standard.

The court interpreted arguments about the non-plausibility of the plaintiff actually taking the defendant's classes as going to standing and found that the plaintiff had established past injury under the ADA, but the defendant was permitted to take jurisdictional discovery on the issue of whether the plaintiff intends to return.

In conclusion, this case shows that website accessibility is a significant issue for visually impaired individuals and businesses must ensure that their websites comply with Title III of the ADA. Businesses should take proactive measures to ensure their websites are accessible and comply with the ADA, even if there is no physical location. This case also demonstrates the importance of establishing standing when bringing a claim under the ADA.

Young v. Metro Learning Inst. Inc., 2023 U.S. Dist. LEXIS 23206

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