Yan Luis v. Alt Fragrances LLC

Background

Kevin Yan Luis sued Alt Fragrances LLC on behalf of himself and others similarly situated. He alleged that Alt Fragrances’ website was not accessible to visually impaired people, violating the Americans with Disabilities Act, the New York State Human Rights Law, the New York State Civil Rights Law, and the New York City Human Rights Law.

The complaint alleged that Yan Luis made “numerous attempts” to complete a purchase on the website, including an online purchase of cologne, and that he intended to visit the website in the future to purchase fragrances because he enjoyed the selections available there.

Standing Issue

Standing is the legal requirement that a person show a sufficient connection to the dispute to ask a federal court to decide it. The court had authority to consider standing even without a party requesting that review. On April 3, 2023, the court concluded that the complaint likely did not adequately allege standing under the governing Second Circuit precedent. The court ordered Yan Luis to explain why the case should not be dismissed and twice extended his deadline to respond. His final deadline was May 5, 2023, but he did not respond.

The court held that the complaint’s vague assertions were insufficient. In particular, Yan Luis did not provide details about how often he visited the website, what items he intended to purchase on each occasion, why he sought to purchase those items from Alt Fragrances specifically, or what unique items he wanted to purchase from the company in the future.

Disposition

The court dismissed the case without prejudice for lack of standing. It also directed the Clerk of Court to close all open motions and close the case. The order did not decide whether Alt Fragrances violated any of the disability-rights laws; it ended the case because the court found that Yan Luis had not adequately shown that he could bring the claims.

Result

The case was dismissed without prejudice for lack of standing.