Mejico v. Alba Web Designs, LLC, 515 F.Supp.3d 424

Plaintiff Brittney Mejico is a blind California resident who uses screen‑reader software to access websites; she alleges Alba Web Designs, LLC operates 500labels.com, a commercial website selling personalized address labels.
Mejico visited the Website multiple times (Sept. 2019–May 2020) and encountered specific accessibility barriers (e.g., missing/empty form labels and links, unlabeled fields, partially screen‑reader‑readable PDF order form) that prevented completing purchases.
Because the PDF order form is only partially accessible, Mejico must obtain sighted assistance to order by mail, causing delay and exclusion from equal access to Alba’s services.
Mejico seeks injunctive relief under Title III of the ADA (and initially asserted a state Unruh Act claim later dismissed); she also describes herself as an ADA “tester” and intends to return to the Website.
Alba moved to dismiss for lack of subject‑matter jurisdiction (standing) and for judgment on the pleadings, arguing Mejico lacks standing and that a website is not a "place of public accommodation." The court denied both motions as to the ADA claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing / Injury in Fact and likelihood of future injury	Mejico alleges concrete past injuries from repeated attempts to use the Website, and pleads plausible intent to return for personal and volunteer uses, so she faces a real likelihood of future injury and thus has standing.	Alba contends Mejico has no Article III injury because she did not complete a purchase and her tester status and litigation history undercut any plausible intent to return.	Court: Allegations of repeated failed access, concrete harms, and plausible intent to return suffice at pleading stage; standing denied as to neither the injury nor the future‑injury requirement.
Whether a commercial website is a "place of public accommodation" under Title III	A commercial website that offers goods/services to the public falls within Title III’s broad categories (e.g., sales or service establishments) and must be accessible; excluding websites would frustrate ADA purposes.	Alba argues "place" implies a physical, brick‑and‑mortar location, so a purely online website is not a Title III public accommodation.	Court: Adopts a non‑physical reading of "public accommodation;" commercial websites can qualify as sales or service establishments under §12181(7); denial of judgment on the pleadings.

Nanni v. Aberdeen Marketplace, Inc., 878 F.3d 447 (4th Cir. 2017) (past encounter with barriers plus intent to return supports standing for injunctive relief)
Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (injury‑in‑fact must be concrete and particularized)
Kenny v. Wilson, 885 F.3d 280 (4th Cir. 2018) (standing analysis and pleading standard for ADA website claims)
Griffin v. Dep’t of Labor Fed. Credit Union, 912 F.3d 649 (4th Cir. 2019) (tester status insufficient without plausible intent to avail oneself of services)
PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001) (Title III’s scope not limited to customers or clients; broad remedial purpose)
Carparts Distrib. Ctr., Inc. v. Auto. Wholesaler’s Ass’n of New England, Inc., 37 F.3d 12 (1st Cir. 1994) (public accommodation not limited to physical structures; services conducted by phone/mail fall within Title III)
Nat’l Ass’n of the Deaf v. Netflix, Inc., 869 F. Supp. 2d 196 (D. Mass. 2012) (construing ADA to cover web‑based services to avoid absurd results)
Nat’l Ass’n of the Blind v. Scribd Inc., 97 F. Supp. 3d 565 (D. Vt. 2015) (websites providing access to goods/services can be subject to Title III)
Packingham v. North Carolina, 137 S. Ct. 1730 (2017) (Supreme Court characterizes cyberspace as an important place for exchange of views)
South Dakota v. Wayfair, 138 S. Ct. 2080 (2018) (modern commerce permits meaningful presence without traditional physical presence)