Robles v. Domino's Pizza, LLC, No. 17-55504 (9th Cir. 2019)
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The Ninth Circuit reversed the district court's dismissal of plaintiff's action alleging that Domino's Pizza's website and mobile application were not fully accessible to a blind or visually impaired person, in violation of Title III of the Americans with Disabilities Act (ADA) and California's Unruh Civil Rights Act.
The panel held that the ADA applied to Domino's website and app, a place of public accommodation, which connected customers to the goods and services of Domino's physical restaurants. The panel also held that imposing liability on Domino's under the ADA would not violate the company's Fourth Amendment right to due process where the statute was not impermissibly vague, Domino's had received fair notice of compliance, and plaintiff did not seek to impose liability on Domino's for failure to comply with the Web Content Accessibility Guidelines 2.0, private industry standards for website accessibility. Furthermore, the lack of specific regulations did not eliminate Domino's statutory duty. Finally, the panel held that the district court erred by applying the prudential doctrine of primary jurisdiction and the district court's ruling unduly delayed the resolution of an issue that could be decided by the court.
Court Description: Americans with Disabilities Act The panel reversed the district court’s dismissal of an action under Title III of the Americans with Disabilities Act and California’s Unruh Civil Rights Act, alleging that Domino’s Pizza’s website and mobile application were not fully accessible to a blind or visually impaired person. The panel held that the ADA applied to Domino’s website and app because the Act mandates that places of public accommodation, like Domino’s, provide auxiliary aids and services to make visual materials available to individuals who are blind. Even though customers primarily accessed the website and app away from Domino’s physical restaurants, the panel stated that the ADA applies to the services of a public accommodation, not services in a place of public accommodation. The panel stated that the website and app connected customers to the goods and services of Domino’s physical restaurants. The panel held that imposing liability on Domino’s under the ADA would not violate the company’s Fourteenth Amendment right to due process. The panel held that the statute was not impermissibly vague, and Domino’s had received fair notice that its website and app must comply with the ADA. Further, the plaintiff did not seek to impose liability on Domino’s for failure to comply with the Web Content Accessibility Guidelines 2.0, private industry
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