Young v. Beekman Arms-Delamater Inn, Inc.
- Edgardo Ramos
- 1:22-cv-06209
- U.S. District Court · Southern District of New York
- 8
Young v. Beekman Arms-Delamater Inn, Judge Ramos denied Beekman’s motion to strike Young’s class allegations before discovery.
The ruling allowed Leshawn Young’s proposed nationwide, New York State, and New York City class allegations to remain in the case for further proceedings. It affected Young and Beekman Arms-Delamater Inn, Inc.; it did not certify any class or decide the underlying claims.
What happened
In Young v. Beekman Arms-Delamater Inn, Leshawn Young, a legally blind person, alleged that Beekman’s restaurant website was inaccessible to blind and visually impaired users. She brought claims under the Americans with Disabilities Act and related New York State and New York City laws, seeking to represent nationwide, state, and city classes.
Beekman asked the court to remove the class allegations from the case. It argued that class certification was unnecessary because an injunction benefiting Young would also benefit website users, and that the disability law claim could not support a class seeking money damages. Young argued that removing the allegations before discovery would be premature because the state and city claims sought money damages.
Judge Ramos denied Beekman’s motion. He ruled that Beekman had not shown from the complaint alone that class certification would be impossible, and that discovery could provide information relevant to whether the proposed classes meet the requirements for certification. The court did not decide whether to certify the classes.
The detailed version
- Young v. Beekman Arms-Delamater Inn, Inc. · No. 1:22-cv-06209
- Edgardo Ramos
- Aug. 16, 2023
Background
Leshawn Young, who is legally blind and uses screen-reading software, alleged that Beekman Arms-Delamater Inn, Inc. operated a website that was not fully accessible to blind or visually impaired people. She alleged that, during visits to the website, she encountered barriers including missing alternative text, empty links, redundant links, missing alternative text for linked images, repetitive title elements, and broken links. She said she could not obtain information about gift certificates, food items, other products, the restaurant’s location, hours, pricing, and privacy policies.
Young filed claims under Title III of the Americans with Disabilities Act, the New York State Human Rights Law, the New York City Human Rights Law, and for declaratory judgment. She brought the case as a proposed class action, seeking certification of a nationwide class of legally blind people who allegedly were denied equal access to Beekman’s website, along with New York State and New York City subclasses. The complaint sought injunctive and declaratory relief and, under the state and city claims, money damages.
Motion to Strike
Beekman moved under Federal Rule of Civil Procedure 12(f) to strike the class allegations. A motion to strike asks the court to remove material from a pleading when it is legally insufficient or otherwise improper. Beekman argued that class certification was unnecessary because any injunction requiring changes to its website would be available to all users. It also argued that Title III of the ADA does not allow money damages and therefore could not support a class under Rule 23(b)(3), which concerns classes in which common questions predominate and a class action is the superior method for resolving the dispute.
Young argued that striking the class allegations before discovery would be premature. She pointed out that the complaint also sought money damages under the New York State and New York City laws.
Court’s Analysis
The court explained that motions to strike class allegations are generally disfavored. At this stage, a defendant must show from the face of the complaint that it would be impossible to certify the proposed class regardless of facts that discovery might reveal. Courts commonly defer the class-certification decision until after discovery provides a more complete factual record.
Judge Ramos concluded that Beekman had not made the required showing. The complaint alleged that common website-accessibility problems affected Young and an entire class of blind individuals, and discovery could provide information about the affected group and how members were affected. The court also rejected Beekman’s argument that an injunction would necessarily benefit all potential class members, because Young’s complaint sought money damages under state and city law in addition to injunctive and declaratory relief.
The court emphasized that Beekman could challenge class certification after discovery under the detailed requirements of Rule 23. It declined to remove the class allegations before that stage because circumstances existed under which the proposed classes could later be certified.
Disposition
The court DENIED Beekman’s motion to strike class allegations. It did not certify the proposed classes or decide the underlying accessibility claims. The parties were directed to appear for a telephonic status conference on September 25, 2023, and the clerk was directed to terminate the motion.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.