Maddy v. Life Time, Inc.

Background

Veronica Maddy alleged that she is visually impaired and legally blind and uses screen-reading software to read website content. She alleged that she repeatedly tried to buy body oil through Life Time’s website, most recently in October 2022, but could not complete the purchase because of accessibility barriers. The alleged barriers included missing alternative text for graphics, inaccessible menus, inaccurate navigation links, inadequate labels and prompts, limited keyboard access, redundant links, and requirements that transactions be completed only with a mouse.

Maddy also alleged that the website prevented her from becoming a member of Life Time’s health centers. She stated that she intended to return to the website immediately if it became accessible, including to purchase Morroccanoil Dry Body Oil. She alleged that she collects body lotions and oils from different brands and wanted to add that product to her collection. Her amended complaint asserted claims under 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, along with a claim for declaratory relief.

Life Time’s Motion

Life Time moved under Federal Rule of Civil Procedure 12(b)(1), which permits dismissal when the court lacks subject-matter jurisdiction. Life Time argued that Maddy lacked constitutional standing—the legal requirement that a plaintiff show a concrete injury connected to the defendant’s conduct and capable of being remedied by a court. Life Time also asked, alternatively, for limited discovery into the standing issue.

Life Time argued that Maddy’s amended allegations about immediately returning to the website were inconsistent with her original complaint and with other complaints she had filed. It also argued that her allegations did not plausibly show that she intended to return to Life Time’s website or join a Life Time health center. Life Time submitted declarations stating that it did not operate a club in the Bronx, that relatively few Manhattan club members lived in the Bronx, and that other health clubs were closer to Maddy’s home. It also argued that many other retailers sold the same body-oil product.

Maddy argued that her allegations adequately established standing and that her repeated filing of similar accessibility lawsuits did not make her allegations false. She also argued that Life Time was improperly relying on evidence outside the complaint. In response to Life Time’s evidence, Maddy submitted an affidavit describing her interest in body oils and lotions, her practice of sending products to family in Ghana, her interest in joining a health club with more amenities, and her willingness to travel to Life Time’s Midtown location.

Court’s Analysis

The court explained that a person seeking an injunction for past accessibility discrimination must plausibly allege past harm, a reasonable likelihood that the discriminatory condition will continue, and a reasonable intent to return to the public accommodation. The court held that Maddy’s amended complaint adequately alleged all three requirements. Her allegations about repeated visits, specific website barriers, and her attempted purchase were sufficient to plead past injury. The alleged continuing barriers supported an inference that the problem would continue. Her stated interest in a specific product, combined with her alleged hobby of collecting body lotions and oils, made her intent to return more specific than the conclusory allegations rejected in another case discussed by the court.

The court also held that Maddy’s filing of more than seventy similar lawsuits did not, by itself, make her standing allegations implausible. The court distinguished a prior appellate decision in which the complaints contained conclusory allegations and other errors, oddities, and omissions. According to the court, Maddy’s amended complaint provided specific facts about the product she wanted and why she wanted it.

The court recognized that the differences between Maddy’s original complaint and amended complaint raised questions about whether her newly stated interests were genuine. But the court held that those differences did not require dismissal at this stage. The amended complaint replaced the original complaint, and the differences could be viewed as additional detail rather than a direct contradiction.

The court nevertheless found that Life Time’s outside evidence raised substantial questions about standing. The court questioned, among other things, Maddy’s interest in traveling to the Midtown club when other clubs were apparently closer and her interest in buying a product available from many other retailers. The court also noted that some of Life Time’s evidence was submitted with its reply, so Maddy had not had an opportunity to respond fully. The court declined to decide the factual standing issue before that process occurred.

Ruling and Case Status

Judge Liman denied Life Time’s motion to dismiss. He granted Life Time’s request for limited jurisdictional discovery into standing, allowing Life Time until August 29, 2023, to conduct that discovery. The court stated that Life Time could later file an appropriate motion if the discovery called Maddy’s standing into question. The court stayed all remaining discovery pending further order and directed the parties to report by August 29, 2023, on whether the stay should be lifted. The order did not decide the merits of Maddy’s disability-access claims.