LUCIUS v. PRESIDENTE SUPERMARKETS MGT., INC.

• After activating the accessibility widget and navigating to the sale images, those images are not announced. Only the navigation arrows are announced but the sale images are not. The labels for the "Search Result" field is unclear when announced to the user. Only "Clickable" is announced, providing no context that this field is for the number of search results per page.
• The weekly specials PDF is not accessible to screen reader users which prevents them from hearing the weekly promotions. For example, all 17 store locations are announced as soon as the PDF is opened but they are read out of order so users hear all of the phone numbers announced at once, then the first address from each location is announced and then users hear all of the store names at once so blind users cannot tell which address is connected to which store name or phone number.
• In addition, Tab key navigation is not possible and arrow keys randomly take users to blank elements.
• The weekly promotions page contains multiple ad images but the content in the images are not announced to screen reader users.
• The label for "Search Radius" field is announced as "Clickable 50 Miles" by the screen reader.
• The onscreen label is not associated to this field so it's not announced when users navigate to this element.

VIOLATION OF TITLE III OF THE AMERICANS WITH DISABILITIES ACT

• The Court issue a declaratory judgment that determines that the defendant's website at the commencement of the subject lawsuit is in violation of Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
• the court issue a declaratory judgment that determines that the defendant's website is in violation of Title III of the Americans with Disabilities Act, 42 U.S.C. § 12181 et seq.
• The Court issue a Declaratory Judgment that Defendant has violated the ADA by failing to monitor and maintain its website to ensure that it is readily accessible to and usable by persons with vision impairment
• That this Court issue an Order directing Defendant to alter its website to make it accessible to, and useable by, individuals with disabilities to the full extent required by Title III of the ADA
• That this Court enter an Order directing Defendant to evaluate and neutralize its policies and procedures towards persons with disabilities for such reasonable time so as to allow Defendant to undertake and complete corrective procedures
• That this Court enter an Order directing Defendant to continually update and maintain its website to ensure that it remains fully accessible to and usable by visually impaired individuals
• An award of attorney’s fees, costs and litigation expenses pursuant to 42 U.S.C. § 12205
• Such other relief as the Court deems just and proper, and/or is allowable under Title III of the Americans with Disabilities Act.