Young v. Metropolitan Learning Institute, Inc.

Background

Lawrence Young sued Metropolitan Learning Institute, Inc., on behalf of himself and people similarly situated. He alleged that the defendant’s website, www.gettraining.org, was not fully accessible to blind and visually impaired people. Young alleged that he used screen-reading software and encountered barriers including missing alternative text for images, empty and redundant links, missing text for linked images, identical webpage titles, and broken links.

The complaint asserted claims under Title III of the Americans with Disabilities Act, the Rehabilitation Act of 1973, the New York State Human Rights Law, and the New York City Human Rights Law. Young sought injunctions requiring the defendant to stop violating those laws and make its website compliant, a declaration that the website discriminated against blind people, class certification, damages, and fees and costs.

The Motion to Dismiss

The defendant moved to dismiss under Federal Rule of Civil Procedure 12(b)(2), arguing that the court lacked personal jurisdiction. Alternatively, it moved under Rule 12(b)(6), arguing that the complaint failed to state a legally sufficient claim. The court explained that, at this stage, it generally had to accept the complaint’s factual allegations as true.

The court denied the personal-jurisdiction argument because the defendant did not dispute that it was domiciled in New York, where the court sits. The court also noted that the defendant had focused on venue rather than properly moving under the rule governing venue. The court stated that venue would be proper because Young alleged that he accessed the website from within the Southern District of New York.

Pleading Sufficiency

The court rejected the argument that Young’s complaint lacked enough detail. Although the complaint did not identify the particular webpage locations containing each accessibility problem, it identified the types of barriers he allegedly encountered. The court held that this was enough to explain the basis of his claims at the motion-to-dismiss stage.

The defendant also argued that Young could not plausibly be interested in the school’s programs because some courses were directed toward non-English speakers and others involved health-care or construction training. The court rejected that argument. It held that the defendant’s factual assertions about its courses were outside the complaint and generally could not be considered on a Rule 12(b)(6) motion. The court also stated that the defendant had not shown that Young’s alleged interest in the courses was entirely implausible.

Website as a Public Accommodation

The defendant argued that its website was not a “place of public accommodation” under Title III of the Americans with Disabilities Act. The court disagreed, reiterating its agreement with the vast majority of district courts within the Second Circuit that commercial websites are places of public accommodation under Title III.

The court further held that Young plausibly alleged that the defendant denied him equal access to the website because the site was incompatible with his screen-reading software. It rejected the argument that Young needed to show a connection, or “nexus,” between the website and the defendant’s physical locations. The court stated that, under the approach it followed, private commercial websites are places of public accommodation in themselves, so a connection to a physical space was not required.

The court stated that the Rehabilitation Act and New York State Human Rights Law claims were subject to the same legal standard as the Title III claim and therefore did not require separate analysis. It also stated that Young had clearly stated a claim under the New York City Human Rights Law because that law’s standard is more permissive. The court denied the Rule 12(b)(6) motion in its entirety.

Standing and Jurisdictional Discovery

The court separately examined Young’s Article III standing, meaning his constitutional ability to ask a federal court to provide relief. The court explained that a person seeking an injunction in an accessibility case generally must allege a past injury, a reasonable likelihood that the discrimination will continue, and a real intention to return to the place or website involved.

The court found that Young had adequately alleged a past injury. He alleged that he visited the website to obtain information and consider applying for admission and enrolling in online courses, but could not fully use the site because of its accessibility barriers. The court held that these allegations went beyond the allegations of a person visiting only to test for violations, because Young alleged that he wanted to use the information for a decision about enrollment.

The court was less certain about Young’s intention to return. Although his allegations appeared to satisfy that requirement, the court was skeptical about the accuracy of some important allegations concerning the website’s features and his interest in the defendant’s particular services. The court therefore permitted the defendant to conduct discovery focused on whether Young had Article III standing.

Disposition

The court denied the defendant’s motion to dismiss. Before the defendant filed an answer, it was permitted to conduct jurisdictional discovery, which had to be completed by April 10, 2023. The parties were ordered to file a joint status letter by April 21, 2023, and the clerk was directed to terminate the motion on the docket.