MUHAMMAD v. CHOICE HOTELS INTERNATIONAL, INC.

Plaintiff

Name: Rasul Muhammad
Filing date: December 20, 2019
State of filing: Illinois

Defendant

Name: Choice Hotels International, Inc.
Website: www.cambriachicago.com
Industry: Hotel, Restaurant and Leisure
Summary: Choice Hotels International, Inc. owns and operates Hotel One Sixty-Six, a botique hotel on Chicago's Magnificent Mile.

Case Summary

On December 20, 2019, Rasul Muhammad filed a Complaint in Illinois Federal court against Choice Hotels International, Inc.. Plaintiff Rasul Muhammad alleges that www.cambriachicago.com is not accessible per the WCAG 2.1 accessibility standard(s).

Case Details

Plaintiff alleges issues in its Complaint including the following:

The Website does not provide a text equivalent for every non-text element;
The purpose of each link cannot be determined from the link text alone or from the link text and its programmatically determined link context;
Web pages lack titles that describe their topic or purpose;
Headings and labels do not describe topic or purpose;
Keyboard user interfaces lack a mode of operation where the keyboard focus indicator is visible;
The default human language of each web page cannot be programmatically determined;
The human language of each passage or phrase in the content cannot be programmatically determined;
Labels or instructions are not always provided when content requires user input;
Text cannot be resized up to 200 percent without assistive technology so that it may still be viewed without loss of content or functionality;
A mechanism is not always available to bypass blocks of content that are repeated on multiple web pages;
A correct reading sequence is not provided on pages where the sequence in which content is presented affects its meaning;
In content implemented using markup languages, elements do not always have complete start and end tags, are not nested according to their specifications, may contain duplicate attributes, and IDs are not always unique; and
The name and role of all UI elements cannot be programmatically determined; things that can be set by the user cannot be programmatically set; and/or notification of changes to these items is not available to user agents, including assistive technology.

Plaintiff asserts the following cause(s) of action in its Complaint:

Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
Declaratory Relief

Plaintiff seeks the following relief by way of its Complaint:

A Declaratory Judgment that at the commencement of this action CHOICE HOTELS was in violation of the specific requirements of Title III of the ADA described above, and the
relevant implementing regulations of the ADA, in that CHOICE HOTELS took no action that was reasonably calculated to ensure that its Website is fully accessible to, and
independently usable by, individuals with visual disabilities;
A permanent injunction pursuant to 42 U.S.C. § 12188(a)(2) and 28 CFR § 36.504(a) which directs Defendant to take all steps necessary to bring its Website into full compliance with
the requirements set forth in the ADA, and its implementing regulations, so that its Website is fully accessible to, and independently usable by, blind individuals, and which further
directs that the Court shall retain jurisdiction for a period to be determined to ensure that Defendant has adopted and is following an institutional policy that will in fact cause it to
remain fully in compliance with the law—the specific injunctive relief requested by Plaintiff is described more fully in paragraph 8 above;
An award of costs and expenses of this action;
Payment of reasonable attorneys’ fees, pursuant to 42 U.S.C. § 12205 and 28 CFR § 36.505, including costs of monitoring Defendant’s compliance with the judgment;
An order certifying the Class under Fed. R. Civ. P. 23(a) & (b)(2) and/or (b)(3), appointing Plaintiff as Class Representative, and his attorneys as Class Counsel; and
Such other and further relief as this Court deems just and proper.