Martinez v. MyLife.com, Inc.
1:21-cv-04779-BMC
E.D.N.YNov 1, 2021Background
- Plaintiff Pedro Martinez is legally blind and uses screen-reading software to access the internet.
- He attempted to use MyLife.com to check and manage his online reputation but could not fully access the site because its interface is incompatible with his screen reader.
- Martinez sued MyLife.com, Inc. under Title III of the ADA and parallel New York state and city laws, seeking class relief.
- MyLife moved to dismiss, arguing (1) its website is not a "place of public accommodation" under the ADA and (2) Martinez failed to request a reasonable modification.
- The court agreed the website is not a place of public accommodation and dismissed the ADA claim with prejudice.
- The court declined supplemental jurisdiction over the state and city claims and dismissed them without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MyLife.com’s website is a "place of public accommodation" under Title III of the ADA | Website qualifies as a public accommodation—best fits the residual "sales establishment" category and/or standalone websites can be covered | The ADA’s enumerated categories contemplate physical places; standalone websites without brick-and-mortar operations are not covered | Website is not a place of public accommodation; ADA claim fails |
| Whether plaintiff must request a reasonable modification to the website before suing | Implied that a request is not required or was excused | Plaintiff did not request and was not denied a reasonable modification, so claim fails | Court did not reach this argument (dismissal based on first ground) |
| Whether to retain supplemental jurisdiction over state and city claims after dismissing the ADA claim | Plaintiff sought to pursue parallel state/city claims in federal court | Defendant implicitly supported dismissal after ADA claim dismissed | Court declined supplemental jurisdiction and dismissed state and city claims without prejudice |
Key Cases Cited
- Elias v. Rolling Stone LLC, 872 F.3d 97 (2d Cir.) (pleading standard under Rule 12(b)(6))
- Chase Group Alliance LLC v. City of New York Dep’t of Fin., 620 F.3d 146 (2d Cir.) (pleading and inference principles)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S.) (plausibility standard for complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S.) (plausibility and pleading standard)
- Camarillo v. Carrols Corp., 518 F.3d 153 (2d Cir.) (elements of a Title III ADA claim)
- Gil v. Winn-Dixie Stores, Inc., 993 F.3d 1266 (11th Cir.) (websites not places of public accommodation)
- Robles v. Domino’s Pizza, LLC, 913 F.3d 898 (9th Cir.) (websites not places of public accommodation)
- National Federation of the Blind v. Scribd Inc., 97 F. Supp. 3d 565 (D. Vt.) (stand-alone website treated as covered)
- Pallozzi v. Allstate Life Ins. Co., 198 F.3d 28 (2d Cir.) (interpretation of public accommodation categories)
- Hall Street Associates v. Mattel, Inc., 552 U.S. 576 (U.S.) (statutory interpretation principles regarding lists and general terms)