Dominguez v. New York Equestrian Center, LTD.

Background

Yovanny Dominguez brought claims under Title III of the Americans with Disabilities Act (ADA), the New York State Human Rights Law, and the New York City Human Rights Law. The complaint alleged that Dominguez is legally blind and requires screen-reading software to use online content. In 2018, she accessed the defendant’s website and encountered barriers including missing alternative text, empty links, redundant links, and linked images without alternative text.

The defendant operated an equestrian center in New York and maintained a website that provided information about its location and hours, allowed users to make reservations, and offered gift-shop purchases. The defendant was served with the complaint but did not answer or otherwise appear. The Clerk entered a certificate of default, and Dominguez moved for default judgment.

Legal standard

A default means that a defendant is treated as admitting the complaint’s well-pleaded factual allegations about liability. It does not automatically establish that the plaintiff has a valid legal claim, and it does not admit the amount of damages. The plaintiff must still show that the facts state a legitimate cause of action and must prove damages with reasonable certainty.

ADA claim

The court held that the complaint stated a Title III ADA violation. First, Dominguez’s blindness substantially limited the major life activity of seeing, so she qualified as a person with a disability under the ADA. Second, the court held that the defendant’s website was a place of public accommodation. The court relied on Second Circuit precedent stating that Title III guarantees disabled people more than physical access and agreed with district courts that the ADA applies to online forums offering goods and services.

Third, the court held that the alleged website barriers plausibly denied Dominguez a full and equal opportunity to use the website. Because the defendant had defaulted, those well-pleaded allegations were taken as true for purposes of deciding liability. The court therefore concluded that Dominguez stated an ADA claim.

State and city claims

The court concluded that Dominguez also stated a claim under the New York State Human Rights Law because disability-discrimination claims under that law use the same standards as ADA claims. The court further concluded that she stated a claim under the New York City Human Rights Law, which is construed independently and is at least as protective as the federal and state laws involved here.

Remedies and order

The court granted injunctive relief and ordered the defendant to take all necessary steps to bring its website into compliance with the ADA and its implementing regulations within 60 days of the order’s entry. The court found that Dominguez had not established specific damages beyond the fact that she experienced discrimination and could not access the website fully, but it determined that this harm warranted compensation. It awarded her the $500 in compensatory damages she requested.

The court also noted that the ADA and New York City law allow a prevailing party to recover reasonable attorney’s fees and litigation costs. Because Dominguez’s counsel had not submitted billing records or other supporting documentation, the court ordered her to file a properly documented motion for fees and costs within 30 days of the order’s entry.

Disposition

The court granted Dominguez’s motion for entry of default judgment. It awarded $500 in compensatory damages, ordered website changes within 60 days, and required a motion for attorney’s fees and costs within 30 days. The court also directed Dominguez to serve the order on the defendant and file proof of service.