Sookul v. Fresh Clean Threads, Inc., 754 F.Supp.3d 395

Plaintiff Sanjay Sookul, who is legally blind, sued Fresh Clean Threads Inc., an online-only clothing retailer, alleging its website is inaccessible to visually impaired users and thus violates Title III of the Americans with Disabilities Act (ADA) and analogous NY state/city laws.
Plaintiff attempted multiple times to buy t-shirts from Defendant’s website but was hindered by lack of screen-reader accessibility.
Defendant operates no physical, brick-and-mortar stores—its business is conducted exclusively online.
The suit seeks injunctive relief, declaratory judgment, and damages under federal and state anti-discrimination statutes.
Defendant moved to dismiss on grounds of lack of standing and failure to state a claim; court considered both issues.
The district court ultimately found Plaintiff had standing, but failed to state a claim because a standalone website is not a "place of public accommodation" under Title III of the ADA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is a standalone website a “place of public accommodation” under ADA Title III?	Yes; text and purpose of ADA support broad coverage including websites.	No; text and statutory context require a physical location.	No; a standalone website is not covered by Title III.
Does Plaintiff have standing for this ADA/injunctive relief suit?	Yes; sufficiently pled multiple visits, specified barriers, intent to return.	No; standing allegations are formulaic and insufficient, especially for serial litigants.	Yes; Plaintiff alleged enough for standing.
Should state and city law claims be entertained absent federal claims?	Yes; state claims should proceed even if federal claim dismissed.	No; federal court should decline jurisdiction if federal claim is dismissed.	No; state claims dismissed for lack of jurisdiction.
Is declaratory relief appropriate if ADA fails?	Yes; a declaration is necessary to clarify the law and provide relief.	No; it is duplicative and unnecessary if ADA claim fails.	No; ADA declaratory relief dismissed with claim.

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards for plausibility and dismissing conclusory complaints)
Camarillo v. Carrols Corp., 518 F.3d 153 (setting elements for ADA Title III claims)
PGA Tour, Inc. v. Martin, 532 U.S. 661 (ADA Title III's requirement for equal access)
Ford v. Schering-Plough Corp., 145 F.3d 601 (limiting public accommodations to physical spaces under ADA)
Pallozzi v. Allstate Life Insurance Co., 198 F.3d 28 (ADA Title III applies to goods/services of public accommodations, but left open issue of nonphysical businesses)
Boy Scouts of America v. Dale, 530 U.S. 640 ("public accommodation" historically limited to physical businesses)
Lujan v. Defs. of Wildlife, 504 U.S. 555 (Article III standing requirements)
Robles v. Domino's Pizza, LLC, 913 F.3d 898 (ADA Title III covers only websites tied to physical locations)
Gil v. Winn-Dixie Stores, Inc., 993 F.3d 1266 (ADA Title III applies only to physical places, not standalone websites)