Martinez v. Pure Green NYC Wholesale Corp.

CourtDistrict Court, E.D. New York
DecidedMarch 30, 2025
Docket1:23-cv-04247
StatusUnknown

This text of Martinez v. Pure Green NYC Wholesale Corp. (Martinez v. Pure Green NYC Wholesale Corp.) 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
Martinez v. Pure Green NYC Wholesale Corp., (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK —————————————————————X PEDRO MARTINEZ, individually and as the representative of a class of similarly situated persons,

Plaintiff, MEMORANDUM & ORDER

-against- 23-cv-4247 (NRM) (MMH)

PURE GREEN NYC WHOLESALE CORP.,

Defendant. —————————————————————X

NINA R. MORRISON, United States District Judge: Plaintiff Pedro Martinez commenced this putative class action against Defendant Pure Green NYC Wholesale Corporation on June 8, 2023. Complaint (“Compl.”), ECF No. 1. Plaintiff alleges violations of Title III of the Americans with Disabilities Act (“ADA”), New York State Human Rights Law (“NYSHRL”), New York State Civil Rights Law (“NYSCRL”), and New York City Human Rights Law (“NYCHRL”). On May 17, 2024, Defendant filed a motion to dismiss for lack of subject matter jurisdiction. For the reasons set forth below, Defendant’s motion to dismiss is denied. BACKGROUND “When evaluating a motion to dismiss for lack of subject matter jurisdiction, the court accepts all material factual allegations in the complaint as true but does not presume the truthfulness of the complaint’s jurisdictional allegations.” Quezada v. U.S. Wings, Inc., No. 20-CV-10707 (ER), 2021 WL 5827437, at *2 (S.D.N.Y. Dec. 7, 2021). I. Plaintiff’s Allegations

On June 8, 2023, Plaintiff filed this action on behalf of himself and a putative class of similarly disabled persons, seeking certification under Fed. R. Civ. P. 23. See Compl. ¶¶ 50–51. Plaintiff “is [] visually-impaired and legally blind,” and “requires screen-reading software to read website content.” Id. ¶ 2. Plaintiff uses a screen- reading software called Job Access With Speech (“JAWS”) to visit websites. Id. ¶¶ 26, 37. Defendant sells, inter alia, nutrient-dense cold-pressed juices, hand-crafted

smoothies, and açai bowls in its physical stores and allows customers to purchase cold-pressed juices and hand-crafted smoothies for delivery to their home on Defendant’s website puregreen.com. Id. ¶¶ 21, 29–31. On May 31, 2023, June 4, 2023, and other unspecified dates in April and May of 2023, Plaintiff attempted to purchase Defendant’s Immunity Shot and Best Sellers Package for delivery using puregreen.com. Id. ¶¶ 43–44. Plaintiff alleges that he was unable to independently complete purchases due to barriers to accessibility on

Defendant’s website. Id. ¶ 43. Specifically, Plaintiff alleges that he could not access any nutrition labels or use the shopping cart because he could not add or remove products, change the quantity of items, or continue to checkout. Id. ¶ 37. Plaintiff identifies specific barriers that impede access for blind and visually impaired people including failure to provide alternative text (“alt-text”) on graphics, inaccessible image maps, inappropriate navigation links, inadequate labeling and prompting, inaccessible drop-down menus, empty and redundant links, and a requirement that transactions be performed with a mouse instead of a keyboard. Id. ¶¶ 34, 38.

Plaintiff explains that many important images on puregreen.com do not have alt-text — written descriptions of images that screen-readers can read aloud. Id. ¶ 35. Without a text equivalent, screen-readers cannot convey the content, context, or purpose of images to blind people. See id. Plaintiff alleges that since there is no alt-text, he and other blind customers are unable to browse the website. Id. The website’s image maps (which combine multiple words and links into one image that

allows users to navigate to multiple destinations within the website) also allegedly do not contain alt-text and are thus also inaccessible to blind users. Id. ¶ 38. Plaintiff alleges that the overall lack of navigation links exacerbates the problems that blind people experience using the website. Id. ¶ 39. Plaintiff further alleges that puregreen.com lacks the necessary prompting information that would allow screen-reader users like himself to locate the online forms necessary to accurately select products, quantity, and frequency of delivery and

to provide personal and financial information on such forms. Id. ¶ 36. This inadequate labeling prohibits blind website users from making purchases or inquiries about Defendant’s products and securely entering their personal and financial information. Id. In addition, Plaintiff alleges that the website’s requirement that transactions be performed with a mouse (as opposed to a keyboard) also denies blind people the ability to independently use the website. Id. ¶ 40. Plaintiff explains that blind people cannot actually use a mouse without the ability to see the pointer. Id. According to Plaintiff, “it is a fundamental tenet of web accessibility that for a page to be accessible

to . . . blind people, it must be possible for the user to interact with the page using only the keyboard.” Id. Plaintiff states that version 2.1 of the Web Content Accessibility Guidelines (“WCAG 2.1”) guideline 2.4.1 requires a mechanism that allows users “to bypass blocks of content that are repeated on multiple webpages because requiring users to extensively tab before reaching the main content is an unacceptable barrier to accessing the website.” Id. ¶ 41. Plaintiff avers that the

website’s inaccessible design, “which requires the use of a mouse to complete a transaction, denies Plaintiff and blind customers the ability to independently make purchases.” Id. ¶ 41. Lastly, Plaintiff alleges that he intends to return to puregreen.com if it becomes accessible in the future and that he “will definitely make purchases of additional products . . . sold on the website.” Id. ¶ 44. He indicates at length his interest in purchasing Defendant’s products from the website. Id. Plaintiff explains

that he “really enjoyed the products” that he purchased in-person at one of Defendant’s retail locations and that he enjoys “the fact that they are an easy way to consume vital nutrients and feel energized and are sold at affordable prices in many flavors.” Id. He states that he prefers Defendant’s products over other “similar items from other (accessible) online vendors” because “he finds them to be delicious and nutrient-dense and . . . more affordable than those sold by others.” Id. Plaintiff notes the specific products he would like delivered to his home in the future — smoothies and cold-pressed juices. Id. Plaintiff avers that Defendant “[failed] to design, construct, maintain, and

operate [its] website to be fully accessible to and independently usable by” visually impaired and blind people, including Plaintiff. Id. ¶ 4. Plaintiff alleges that Defendant’s “denial of full and equal access to its website, and therefore denial of its products and services offered,” violates the ADA. Id. Plaintiff further alleges state law claims under NYSHRL, NYSCRL, and NYCHRL. Id. ¶¶ 77–87, 92–102, 105–12. II. Procedural History A. This Court’s Order Finding that Plaintiff has Standing

On August 14, 2023, Defendant filed two identical letters requesting a premotion conference on a motion to dismiss for a lack of standing. ECF Nos. 9, 10. Defendant argued that Plaintiff could not establish an injury in fact or the requisite reasonable inference of an intent to patronize Defendants’ website. ECF No. 9 at 1– 2; ECF No. 10 at 1–2.1 Defendant also argued that “the instant action is demonstrative of the potential for abuse of the ADA noted in numerous cases in

districts throughout the country” because of Plaintiff’s “vague allegations of past patronage” and “serial litigation history,” and attached a list of over 700 cases filed by Plaintiff’s attorney in the Eastern and Southern District Courts of New York since 2001. ECF No. 9 at 1–2; ECF No. 10 at 1–2 (quotation omitted); ECF No. 10-1 (list of cases).

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