Young v. America Ulike International Inc.
- Vernon Broderick
- 1:25-cv-00754
- U.S. District Court · Southern District of New York
- 2
In Young v. America Ulike, Judge Broderick ordered the parties to explain whether a proposed website-accessibility consent decree satisfies required review.
The parties to the proposed settlement—Les hawn Young and America Ulike International Inc.—and potentially people who might bring similar website-accessibility lawsuits if the requested injunction were entered.
What happened
In Young v. America Ulike International Inc., the parties told the court they had reached a settlement in principle and asked it to approve a proposed consent decree. The decree would require America Ulike International Inc. to use best efforts for 24 months to make its website accessible to people with vision disabilities.
The parties also asked the court to prohibit Young or others from bringing similar website-accessibility lawsuits under federal or comparable state laws. The court did not approve or reject the proposed decree. Instead, it ordered the parties to submit a joint letter by June 30, 2025, explaining whether the court should apply a legal test for consent decrees containing injunctions and whether the proposal satisfies that test.
Judge Broderick directed the parties to discuss the negotiations, information exchanged, financial compensation, and Young’s involvement in approving the decree, among other considerations. The order therefore postpones a decision on the proposed settlement and injunction.
The detailed version
- Young v. America Ulike International Inc. · No. 1:25-cv-00754
- Vernon Broderick
- June 17, 2025
Background
The parties reported that they had reached a settlement in principle and asked the court to approve their proposed consent decree. A consent decree is a court-approved agreement resolving a dispute. The proposed decree would require America Ulike International Inc. to use best efforts, within 24 months, to make its website accessible to people with vision disabilities in accordance with applicable guidelines.
The parties also asked the court to enter an injunction barring Young or other people from bringing similar lawsuits against the defendant alleging similar website-accessibility violations under federal law or similar state laws.
Court’s Analysis
The parties relied on Kozlowski v. Coughlin, which states that a court reviewing a consent decree must determine whether the decree resolves a dispute within the court’s jurisdiction, falls within the general scope of the pleadings, and advances the objectives of the law underlying the complaint.
The court noted that the parties did not address U.S.S.E.C. v. Citigroup Global Markets, Inc., which states that courts reviewing consent decrees containing injunctive relief must evaluate additional considerations, including the decree’s basic legality, its terms and enforcement, and whether it resulted from improper collusion or corruption. The opinion’s quoted statement of the Citigroup factors is incomplete or garbled in the provided text.
The court also cited a prior website-accessibility case applying the Citigroup approach. That decision identified the history and duration of negotiations, information exchanged, financial compensation to the plaintiff and the plaintiff’s lawyer, and the plaintiff’s participation in negotiations and approval as relevant considerations.
Order
The court ordered the parties to submit a joint letter by June 30, 2025, explaining whether the court should apply the Citigroup test and whether the proposed consent decree satisfies it. The parties were directed to address the considerations identified in the cited website-accessibility case as part of that analysis. The order did not approve or reject the proposed consent decree or requested injunction.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.