Constance Henry v. SHEPHERD'S DREAM, LLC

Case Summary

According to the complaint, Constance Henry, a legally blind individual, is suing Shepherd's Dream, LLC for failing to make their website, Shepherdsdream.com, accessible to blind and visually-impaired users. The complaint alleges that the website contains significant access barriers that prevent users from completing transactions independently. Plaintiffs allege violations of the Americans with Disabilities Act, claiming that the website's design excludes blind individuals from accessing the goods and services offered. The plaintiffs seek a permanent injunction requiring the defendant to make the website accessible and compensatory damages for the discrimination experienced.

Causes of Action

• Violation of 42 U.S.C. §§ 12181 et seq. – Title III of the Americans with Disabilities Act
• Declaratory Relief
• Negligent Infliction of Emotional Distress

Key Allegations

• Defendant's website is inaccessible to blind and visually-impaired persons
• Plaintiff encountered multiple accessibility barriers preventing her from completing a purchase
• Defendant failed to comply with the Americans with Disabilities Act

Requested Relief

• A preliminary and permanent injunction to prohibit Defendant from violating the Americans with Disabilities Act
• A declaration that Defendant's website discriminates against the blind
• Compensatory damages in an amount to be determined at trial

Proposed Class

all legally blind individuals in the United States who have attempted to access Shepherdsdream.com and as a result have been denied access to the enjoyment of goods and services offered by Shepherdsdream.com, during the relevant statutory period

Jurisdiction & Venue

This Court has subject-matter jurisdiction under 28 U.S.C. § 1331 and 42 U.S.C. § 12182; venue is proper under 28 U.S.C. §1391(b)(1) and (2) because Defendant conducts business in this District.