Robles v. Two Buds Enterprise, Inc.
- Subramanian
- 1:24-cv-07586
- U.S. District Court · Southern District of New York
- 1
In Robles v. Two Buds Enterprise, Judge Subramanian ordered supplemental briefing before deciding Robles’s default-judgment motion over website-accessibility claims.
Primitivo Robles must file a supplemental brief addressing the ADA-related liability issues and the effect of the earlier decision; Two Buds Enterprise is the defendant whose potential liability remains undecided.
What happened
In Robles v. Two Buds Enterprise, Inc., Primitivo Robles claims that Two Buds Enterprise’s website is inaccessible to visually impaired users and violates the Americans with Disabilities Act and related state and city laws.
Robles asked the court to enter a judgment because the defendant had defaulted. The court said that, even when a defendant defaults, it must still decide whether the complaint provides a legal basis for liability. The court found persuasive an earlier decision about the scope of the Americans with Disabilities Act, but Robles’s filing did not explain why that decision did not prevent his claims or why the court should not follow it.
The court ordered Robles to file a supplemental brief by April 7, 2025, addressing those issues and Two Buds Enterprise’s potential liability under the laws involved. Judge Arun Subramanian did not decide the default-judgment motion or the defendant’s liability in this order.
The detailed version
- Robles v. Two Buds Enterprise, Inc. · No. 1:24-cv-07586
- Subramanian
- Apr. 3, 2025
Background
Primitivo Robles sued Two Buds Enterprise on behalf of himself and others similarly situated. He alleges that the defendant’s website is not accessible to visually impaired users and that this violates the Americans with Disabilities Act (ADA) and corresponding state and city laws.
Motion and Legal Standard
Robles moved for default judgment. The court explained that, on a default-judgment motion, it accepts the complaint’s well-pleaded allegations as true but must still determine whether those allegations establish a legal basis for liability.
Court’s Action
The court had previously found persuasive the analysis in Winegard v. Newsday LLC concerning the scope and applicability of the ADA. Robles’s briefing did not address why that decision did not foreclose his claims or why the court should not follow it. The court ordered Robles to file a supplemental brief by April 7, 2025, addressing those issues and Two Buds Enterprise’s liability under the statutes at issue.
Disposition
The order requires supplemental briefing. It does not grant or deny Robles’s motion for default judgment and does not decide whether Two Buds Enterprise is liable.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.