Yan Luis v. Goldthread LLC

Background

Kevin Yan Luis sued Goldthread, LLC, alleging that Goldthread’s failure to make its website accessible to visually impaired people violated the Americans with Disabilities Act, the New York State Human Rights Law, and the New York City Human Rights Law. The opinion states that the lawsuit was filed on June 10, 2022, and that Luis brought it on behalf of himself and others similarly situated.

Court’s Concern About Standing

On October 11, 2022, the court ordered Luis either to show why the case should not be dismissed for lack of standing or to seek permission to file an amended complaint. Standing is the legal requirement that a plaintiff show a sufficient personal connection to the alleged injury to bring the case. The court said the complaint’s allegations were at least as conclusory as allegations that the Second Circuit had dismissed for failure to establish standing in a cited decision.

Amendment Request and Ruling

Luis filed a one-paragraph letter requesting permission to amend the complaint, but he did not attach the redlined proposed amended complaint required by the judge’s individual practices. The court dismissed that motion without prejudice and ordered Luis to refile it by noon on October 24, 2022. Luis did not file a renewed motion by the deadline.

The court dismissed the case without prejudice for failure to allege standing. It also canceled all previously scheduled conferences and other deadlines, directed the Clerk to terminate all open motions, and closed the case.