Jackson v. Simplisafe, Inc.
- Garnett
- 1:25-cv-04860
- U.S. District Court · Southern District of New York
- 2
In Jackson v. Simplisafe, Inc., Judge Garnett ordered settlement discussions and postponed the defendant’s response deadline.
Sylinia Jackson and Simplisafe, Inc.; the order also directs appearing counsel to notify other parties or their counsel and file proof of notice.
What happened
Jackson v. Simplisafe, Inc. concerns a website-related claim under Title III of the Americans with Disabilities Act. The court ordered the parties to try to settle after the defendant is served.
Within 30 days of service, the parties must meet for at least one hour and discuss settlement, including whether Jackson has standing and whether the website is a standalone website that qualifies as a public accommodation. They must then file a joint letter within 45 days of service reporting whether they settled and proposing mediation, a settlement conference, or an initial status conference if they did not.
Judge Margaret M. Garnett stayed Simplisafe’s deadline to answer or otherwise respond until the joint letter is filed. The order did not decide standing, whether the website is covered by the disability law, or any other claim.
The detailed version
- Jackson v. Simplisafe, Inc. · No. 1:25-cv-04860
- Garnett
- July 7, 2025
Background
The opinion is a case-management order in an action brought by Sylinia Jackson against Simplisafe, Inc. The order refers to a claim involving a website and Title III of the Americans with Disabilities Act, a federal law addressing access to places of public accommodation for people with disabilities.
Settlement and Issues for Discussion
The court ordered the parties to meet and confer for at least one hour within 30 days after service of the summons and complaint on Simplisafe. They must make a good-faith effort to settle the action. Their discussions should include whether Jackson has satisfied the threshold requirement of standing, meaning a sufficient connection to the alleged harm to invoke the court’s authority. They should also discuss whether the website is a “standalone website”—a website for a business without a physical location—and whether such a website is a place of public accommodation under Title III. The order cites decisions in which some courts in the Southern District of New York held that standalone websites are not places of public accommodation under that law.
If the parties cannot settle themselves, they must discuss whether additional settlement efforts through the court’s mediation program or before a magistrate judge would be productive.
Joint Letter and Response Deadline
Within 15 additional days, or 45 days after service of the summons and complaint, the parties must file a joint letter stating whether they settled. If they did not settle, the letter must ask the court either to refer the case to mediation or to a magistrate judge for a settlement conference, while stating a preference, or to proceed with an initial status conference. The letter must also state whether Simplisafe intends to answer or move to dismiss the complaint. If Simplisafe plans to move to dismiss, the letter must briefly state the basis for the anticipated motion in no more than one paragraph.
The court stayed Simplisafe’s deadline to answer or otherwise respond to the complaint. After the joint letter is filed, the court will set either a deadline for the answer or a briefing schedule for a motion to dismiss.
Disposition
Judge Margaret M. Garnett ordered the settlement and reporting procedures described above and stayed the response deadline. The court did not rule on standing, whether the website is a place of public accommodation, or the merits of the action.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.