Castillo v. Jo-Ann Stores, LLC
286 F. Supp. 3d 870
N.D. Ohio2018Background
- Plaintiff Rebecca Castillo, a blind California resident, alleges Jo-Ann Stores' website (joann.com) is inaccessible to screen‑reading software and therefore denies her access to goods and services in violation of Title III of the ADA and California's Unruh Act.
- Castillo alleges she could not use site features (store locator, product browsing, purchasing, in‑store pickup/shipping info, sales/offers) and was deterred from locating or visiting physical Jo‑Ann stores.
- Jo‑Ann moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing (1) the ADA does not apply to websites, (2) Castillo failed to allege the website created an on‑site barrier or a sufficient nexus to physical stores, (3) Castillo lacks standing, and (4) requested injunctive relief would violate due process.
- The court treated the complaint allegations as true for the motion to dismiss and analyzed standing (Spokeo and Lujan principles), whether Parker and Stoutenborough foreclose website‑based ADA claims, and whether Castillo alleged a sufficient nexus between the website and Jo‑Ann’s brick‑and‑mortar stores.
- The court denied the motion to dismiss in full (but struck the request for declaratory relief), holding Castillo has standing, stated a Title III claim because she alleged a sufficient nexus between joann.com and physical stores, and may pursue the Unruh Act claim ancillary to the ADA claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing (injury‑in‑fact) | Castillo says website inaccessibility caused concrete harm (failed attempts to locate stores, complete transactions, obtain information). | Jo‑Ann says allegations are mere technical violations and not concrete under Spokeo. | Court: Castillo alleged a concrete, particularized injury tied to website inaccessibility and has standing. |
| Applicability of Title III to websites | Website can give access to goods/services of physical public accommodations; ADA forbids discrimination in enjoyment of those goods/services. | Jo‑Ann relies on Sixth Circuit precedent (Parker, Stoutenborough) to argue Title III covers only physical places so websites are not covered. | Court: Parker and Stoutenborough do not foreclose website‑based claims; question remains open and the complaint may proceed. |
| Nexus requirement between website and physical place | Castillo asserts joann.com is integrated with stores (store locator, online orders, in‑store pickup, store sales info) and alleged deterrence from visiting stores. | Jo‑Ann says plaintiff must allege a strong nexus and show the website impeded or prevented physical entry to stores. | Court: Allegations here sufficiently plead a nexus (site operates as gateway to stores); dismissal denied. |
| Relief / due process (scope of injunction) | Castillo seeks injunction to require compliance with ADA (no specific technical standard requested). | Jo‑Ann claims injunction would lack standards/notice and violate due process; urges striking relief or dismissal. | Court: Struck declaratory relief but rejected due process dismissal; injunction to comply with ADA is permissible at pleading stage. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard governs Rule 12(b)(6))
- Ashcroft v. Iqbal, 556 U.S. 662 (clarifies Twombly plausibility standard)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing: injury, causation, redressability)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (concrete injury requirement for standing)
- Parker v. Metro. Life Ins. Co., 121 F.3d 1006 (6th Cir. en banc) (interpreting Title III limits; did not decide whether accessing goods/services remotely can support a claim)
- Stoutenborough v. Nat'l Football League, Inc., 59 F.3d 580 (6th Cir. 1995) (Title III claims implicating broadcasts and services distinguished from physical place requirements)
- Rendon v. Valleycrest Prods., 294 F.3d 1279 (11th Cir. 2002) (Title III covers intangible screening procedures that deny access to goods/services of a public accommodation)
- Nat'l Fed'n of the Blind v. Target Corp., 452 F. Supp. 2d 946 (N.D. Cal. 2006) (denying dismissal where inaccessible retail website allegedly impeded enjoyment of in‑store services)