Erkan v. Blue & Cream, LLC

CourtDistrict Court, E.D. New York
DecidedMarch 12, 2025
Docket1:23-cv-06241
StatusUnknown

This text of Erkan v. Blue & Cream, LLC (Erkan v. Blue & Cream, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Erkan v. Blue & Cream, LLC, (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ------------------------------------------------------------- x NIHAL ERKAN, on behalf of herself and all others similarly situated, REPORT AND Plaintiff, RECOMMENDATION

-against- 23 Civ. 6241 (RER) (VMS)

BLUE & CREAM, LLC,

Defendant. ------------------------------------------------------------- x Vera M. Scanlon, United States Magistrate Judge: Plaintiff Nihal Erkan (“Plaintiff”) commenced this action against Defendant Blue & Cream, LLC (“Defendant”), asserting the following claims: (1) violation of the public accessibility requirements of Title III of the Americans with Disabilities Act, 42 U.S.C. §§ 12181 et seq. (the “ADA”); (2) violation of the public accessibility requirements of Article 15 of the New York State Human Rights Law, N.Y. Exec. Law §§ 290 et seq. (the “NYSHRL”); (3) violation of the public accessibility requirements of Article 4 of the New York State Civil Rights Laws, N.Y. Civ. Rights Law §§ 40 et seq. (the “NYSCRL”); and (4) violation of the New York City Human Rights Law, N.Y.C. Admin. Code §§ 8-101 et seq. (the “NYCHRL”). See generally ECF No. 1. Plaintiff’s complaint also seeks declaratory relief. See generally id. Plaintiff moves for entry of a default judgment, seeking (1) a declaration that, through the operation of its website, Defendant violated the ADA, the NYSHRL, the NYSCRL and the NYCHRL; (2) a preliminary and permanent injunction requiring Defendant to bring the website into compliance with the ADA and its implementing regulations; (3) compensatory damages pursuant to the NYSHRL and the NYCHRL in the amount of $1,500.00; (4) pre-judgment and post-judgment interest; and (5) an award of reasonable attorneys’ fees and costs. See ECF No. 14 at 5-6. For the reasons discussed below, the Court respectfully recommends that (1) Plaintiff’s motion be granted in part and denied in part without prejudice, conditioned on timely receipt of the conforming filings described infra, Secs. II (B)(1)(b), by March 19, 2025, and (2) that Plaintiff be permitted to file a motion for attorneys’ fees and costs that conforms with this report and

recommendation by April 2, 2025. I. FACTUAL BACKGROUND Plaintiff, a resident of Queens, is “visually-impaired” and “legally blind,” as she has “a visual acuity with correction of less than or equal to 20 x 200,” and, as such, “requires screen- reading software to read website content using her computer” and a keyboard, as opposed to a mouse. ECF No. 1 ¶¶ 2, 15, 20, 29. Use of this software requires that “the information on a website . . . be capable of being rendered into text.” Id. ¶ 21. Defendant “specializes in designer women’s and men’s clothing . . . and accessories.” Id. ¶ 5. Defendant has a website, which it “controls and operates . . . in New York State and throughout the United States,” located at https://www.blueandcream.com (the “Website”). Id. ¶¶

4, 24. The Website “provides to the public a wide array of services,” including information about “price specials,” “information about store locations and hours of operation, . . . information about the services in its physical locations, . . . information about available offers and programs,” social media connections, information about Defendant, and blog posts. Id. ¶¶ 5, 26. Defendant failed “to design, construct, maintain, and operate [its] . . . website to be fully accessible to and independently usable by Plaintiff.” Id. ¶ 4; see id. ¶ 5 (noting the “significant access barriers that . . . make it impossible for blind and visually-impaired users to enjoy and learn about the services at Blueandcream.com prior to entering Defendant’s physical location”). The barriers include “inaccurate heading hierarchy, incorrectly formatted lists, inaccessible contact information, changing of content without advance[d] warning, unclear labels for interactive elements, inaccurate drop-down menus, the denial of keyboard access for some interactive elements, redundant links . . . , . . . the requirement that transactions be performed solely with a mouse,” lack of alternative text for images, lack of “prompting information and

accommodations” for screen-readers to locate and complete online forms, and lack of adequate labeling. Id. ¶¶ 29-31, 33. The Website “rel[ies] on an exclusively visual interface,” requiring “blind persons [to] . . . rely on sighted companions to assist them in accessing Blueandcream.com.” Id. ¶ 7. Plaintiff engages in “an active lifestyle and wears comfortable and minimalist clothing,” such that “[s]he was looking for an online store providing stylish[,] high-quality dresses from local designers.” Id. ¶ 10. In her search, she discovered the Website, “wanted to buy a stretching dress,” and wanted “to find out the store’s hours of operations, but[,] due to numerous accessibility issues, [she] could not complete the purchase” or carry out her intention to visit Defendant’s physical store on Madison Avenue. Id. ¶¶ 10, 17-18. The accessibility issues

encountered by Plaintiff in visiting the Website include disorientation resulting from an automatic pop-up window, improperly defined heading hierarchies, an improperly formatted navigation menu, issues with search suggestions, improper programming of interactive elements, announcement of repetitive links without context, inability to navigate through content, direction to the same destinations, inappropriate and nondescriptive names for interactive elements, poorly descriptive alternative text, and inaccessibility of Defendant’s phone number. See id. ¶ 32. Plaintiff’s attempts to use the Website, which took place on August 4, 2023, and on August 5, 2023, were made from this District. Id. ¶¶ 13, 36. Plaintiff plans to use the Website “immediately” upon it being made accessible and “would like to visit one of . . . Defendant’s physical store locations.” Id. ¶ 37. II. DISCUSSION Federal Rule of Civil Procedure 55 sets forth the two-step procedure “for the entry of

judgment against a party who fails to defend: first the entry of a default, and second, the entry of a default judgment.” City of N.Y. v. Mickalis Pawn Shop, LLC, 645 F.3d 114, 128 (2d Cir. 2011 (citation omitted). A. Entry Of A Default Federal Rule of Civil Procedure 55(a), entitled “Entering a Default,” provides that, “[w]hen a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown by affidavit or otherwise, the clerk must enter the party’s default.” Local Civil Rule 55.11 requires a party seeking an entry of default to file (a) a request for an entry of default; (b) an affidavit demonstrating that (1) “the party against whom a notation of default is sought is not an infant, in the military, or an incompetent person”; that (2)

“the party has failed to plead or otherwise defend the action”; (3) that “the pleading to which no response has been made was properly served; and (c) a proposed form of default. Local Civ. R.

1 Local Civil Rule 1.1 provides that “[t]hese Local Civil Rules take effect on January 2, 2025 (the “Effective Date”) and govern actions pending or filed on or after that date.

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Erkan v. Blue & Cream, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/erkan-v-blue-cream-llc-nyed-2025.