Hippe v. Circuit City Corporation Inc

CourtDistrict Court, E.D. Wisconsin
DecidedAugust 19, 2025
Docket2:25-cv-00298
StatusUnknown

This text of Hippe v. Circuit City Corporation Inc (Hippe v. Circuit City Corporation Inc) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hippe v. Circuit City Corporation Inc, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

XINYUE HIPPE,

Plaintiff, Case No. 25-cv-298-pp v.

CIRCUIT CITY CORPORATION, INC.,

Defendant.

ORDER GRANTING IN PART AND DENYING IN PART MOTION FOR DEFAULT JUDGMENT (DKT. NO. 12)

On February 28, 2025, the plaintiff filed a class action complaint alleging that the defendant had violated Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. §§12181 et seq., because the website circuitcity.com is not formatted to allow a legally blind customer like the plaintiff to access its content. Dkt. No. 1. The affidavit of service reflects that the summons and complaint were served on March 5, 2025. Dkt. No. 2. The defendant has not appeared or answered the complaint. On May 23, 2025, the plaintiff asked the clerk to enter default, dkt. no. 10, and the clerk did so four days later. The plaintiff then filed the instant motion for default judgment, seeking declaratory and injunctive relief, damages and attorneys’ fees. Dkt. No. 12. I. Entry of Default Federal Rule of Civil Procedure 55 requires a two-step process before the entry of default judgment. A party first must seek an entry of default based on the opposing party’s failure to plead. Fed. R. Civ. P. 55(a). This means that the court must assure itself that the defendant was aware of the suit and still did not respond. Under Federal Rule of Civil Procedure 4, a plaintiff may serve a corporate

defendant “by delivering a copy of the summons and of the complaint to an officer, a managing or general agent, or any other agent authorized by appointment or by law to receive service of process.” Fed. R. Civ. P. 4(h)(1)(B). The process server’s affidavit of service states that on March 5, 2025, she served the summons and complaint on John Downey with Harvard Business Services, Inc., who she asserts is designated by law to accept service of process on behalf of the defendant. Dkt. No. 2. The defendant is a Delaware corporation, dkt. no. 1 at ¶20, and Delaware’s Division of Corporations reflects

that Harvard Business Services is the defendant’s registered agent. See https://icis.corp.delaware.gov/ecorp/entitysearch/namesearch.aspx (search term: “Circuit City Corporation”). The court finds that the plaintiff properly effected service on the defendant by serving its registered agent. II. Plaintiff’s Motion for Default Judgment After the entry of default, the plaintiff may move for default judgment under Rule 55(b). Fed. R. Civ. P. 55(b). When the court determines that a

defendant is in default, the court accepts as true the well-pleaded allegations in the complaint. e360 Insight v. The Spamhaus Project, 500 F.3d 594, 602 (7th Cir. 2007). “A default judgment establishes, as a matter of law, that defendants are liable to plaintiff on each cause of action in the complaint.” Id. A. Factual Allegations The plaintiff asserts that default judgment is proper because the defendant “owns and operates a website (https://Circuitcity.com) that contains multiple barriers that deny blind and visually impaired individuals full and

equal access to its goods and services” in violation of Title III of the ADA. Dkt. No. 12 at ¶¶1–2. The plaintiff is legally blind and cannot use a computer without the assistance of screen reader software to read digital content. Dkt. No. 1 at ¶19. Screen reader software “vocalizes visual information on a computer screen” and uses auditory cues to allow a visually impaired user to effectively use websites. Id. at ¶23; see also Andrews v. Blick Art Materials, LLC, 286 F. Supp. 3d 365, 374 (E.D.N.Y. 2017) (describing the functions of screen reader software). For the screen reader software to function, the

website’s content must be capable of being rendered into text; otherwise, the blind user is not able to access the content of the website. Dkt. No. 1 at ¶24. The plaintiff alleges that circuitcity.com “contains access barriers” to blind users using screen reader software. Id. at ¶32. The plaintiff lists several examples of these barriers. Id. First, the plaintiff states that several images on circuitcity.com lack a text description, or “alt-text,” that would allow the screen reader to accurately describe the image to the user. Id. at ¶33. The plaintiff

states that circuitcity.com also “lacks prompting information” that would allow a blind user to locate and accurately complete forms to make purchases or inquiries about the defendant’s merchandise. Id. at ¶34. Other issues the plaintiff identifies include missing or inaccurate menu headings, hidden elements that were not vocalized by a screen reader, sub-menus that were not vocalized or accessible via keyboard commands and links that open new windows without warning and prevent the user from moving between pages. Id. at ¶35. The plaintiff also alleges that the website requires the use of a mouse to

complete a transaction, but many blind users cannot use a mouse because moving a mouse’s cursor on the screen requires vision. Id. at ¶36. The plaintiff asserts that as a result, “blind customers are essentially prevented from purchasing any items” on the website. Id. at ¶¶35–36. The plaintiff alleges that she attempted to purchase new headphones from the defendant’s website, but that the interactive elements on the site were not readable by her screen reader and that she was unable to complete the purchase on her own. Id. at ¶39. The plaintiff states that she remains

interested in purchasing products on the defendant’s website and will immediately access the website again once the defendant corrects the current accessibility barriers. Id. at ¶40. The complaint brings three causes of action. The first alleges that the defendant violated Title III of the ADA and seeks an injunction to prevent further violations. Id. at ¶¶56–70. The second cause of action seeks a declaration that the defendant violated Title III. Id. at ¶¶71–73. The third cause

of action alleges negligent infliction of emotional distress. Id. at ¶¶74–77. The complaint seeks declaratory and injunctive relief; nominal, compensatory and punitive damages; and attorneys’ fees and costs. Id. at 19–20. The complaint also contains class action allegations. Id. at ¶¶50–55. But the plaintiff appears to have abandoned her class claims in the motion for default judgment. The plaintiff does not seek class damages and has not moved for class certification under Federal Rule of Civil Procedure 23(c)(1). “Class

damages cannot be awarded if no class is certified.” Davis v. Hutchins, 321 F.3d 641, 648 (7th Cir. 2003) (vacating award of class damages and affirming default judgment on an individual basis where no class was certified in the district court). The court will construe the motion for default judgment as seeking default judgment only on an individual basis. See Hippe v. Favorite Daughter Holdings LLC, Case No. 25-cv-475, Dkt. No. 11 at 1 (E.D. Wis.

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