Sumlin v. New York Beer Co., LLC

CourtDistrict Court, S.D. New York
DecidedJune 18, 2025
Docket1:24-cv-08448
StatusUnknown

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

Bluebook
Sumlin v. New York Beer Co., LLC, (S.D.N.Y. 2025).

Opinion

USDC SDNY UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK DOC #: nnn nnn nnn nnn nnn acca DATE FILED:_ 6/18/2025 DENNIS SUMLIN, on behalf of himself and all others . similarly situated, : Plaintiff, 24-cv-8448 (LJL) -v- OPINION AND ORDER NEW YORK BEER CO., LLC, Defendant.

LEWIS J. LIMAN, United States District Judge: Plaintiff Dennis Sumlin (“Sumlin” or “Plaintiff’), on behalf of himself and all others similarly situated, brings claims against Defendant New York Beer Co., LLC (“New York Beer” or “Defendant”) under the Americans with Disabilities Act (“ADA”), the New York City Human Rights Law (““NYCHRL”), and the New York State Human Rights Law (“NYSHRL”). Dkt. No. 1 “Complaint” or “Compl.”). Plaintiff now moves for a default judgment pursuant to Federal Rule of Civil Procedure 55(b)(2). Dkt. No. 17. For the following reasons, the motion for default judgment is granted. BACKGROUND The following facts are drawn from Plaintiff's Complaint and are accepted as true for purposes of this motion. Plaintiff is a resident of New York County, New York. Compl. § 15. He is legally blind. Id. 4 16. Like many visually-impaired people, Plaintiff uses screen reading technology to navigate the internet. /d. 20. A screen reader reads out a website’s information to its user. /d.

A website must have “alternative text” embedded in graphics so that the screen reader can describe the image to its user. Id. ¶ 21. The Defendant, New York Beer Co., LLC, controls and operates a website with the address jacobspickles.com (the “Website”). Id. ¶¶ 24, 36. The Website is connected to Jacob’s

Pickles, a Southern-inspired restaurant which is known for its comfort food, including items like homemade pickles, fried chicken, and biscuits. Id. ¶¶ 25–26. One of Jacob’s Pickles’ locations is on the Upper West Side of Manhattan. Id. ¶ 37. From the Website, a patron can view menus, order food, get information about restaurant locations, book private events, purchase “Jacob’s Pickles” merchandise, and make reservations. Id. ¶ 26. On October 25, 2024, Plaintiff attempted to access the Website with his screen reader. Id. ¶ 36. He browsed the Website to explore Jacob’s Pickles’ menu and get a sense of the dishes it offered to make a reservation. Id. As he did so, he noticed that the Website offered branded merchandise. Id. He attempted to add a branded T-shirt to his cart. Id. However, he encountered accessibility issues, “such as external links opening in new windows without

notification, elements that could not be focused on using the Tab key, and ambiguous links that did not clearly indicate their destination or function.” Id. These accessibility issues kept Plaintiff from exploring and shopping on the Website. Id. Plaintiff is still interested in Defendant’s services and hopes to visit Jacobs Pickles’ physical locations in the future, specifically the location on the Upper West Side. Id. He will also visit the Website again as soon as Defendants ameliorate the accessibility issues. Id. ¶ 37. PROCEDURAL HISTORY On November 6, 2024, Plaintiff commenced this action on behalf of himself and all others similarly situated. Dkt. No. 1. The Complaint and Summons were served on Defendant through the New York Secretary of State on November 25, 2025, and proof of service was filed on December 1, 2024. Dkt. No. 6. Defendant has not appeared. On April 16, 2025, Plaintiff filed a proposed Clerk’s Certificate of Default pursuant to Local Civil Rule 55.1. Dkt. No. 13. On April 16, 2025, the Clerk’s Certificate of Default was

entered. Dkt. No. 15. On April 18, 2025, Plaintiff moved for a default judgment. Dkt. Nos. 16– 17. Plaintiff served the motion for default judgment on the Defendant the same day through the Secretary of State. Dkt. No. 18. Defendant has not appeared and has not filed a response to the motion. LEGAL STANDARD “Rule 55 of the Federal Rules of Civil Procedure provides a two-step process for obtaining a default judgment.” Priestley v. Headminder, Inc., 647 F.3d 497, 504 (2d Cir. 2011). First, when a party against whom relief is sought has failed to plead or otherwise defend, and such failure is demonstrated by affidavit, the clerk must enter the default. Fed. R. Civ. P. 55(a). This simply “formalizes a judicial recognition that a defendant has, through its failure to defend the action, admitted liability to the plaintiff.” Mintable PTE Ltd. v. Mintology, Inc., 2024 WL

3454825, at *4 (S.D.N.Y July 18, 2024) (citing City of New York v. Mickalis Pawn Shop, LLC, 645 F.3d 114, 128 (2d Cir. 2011)). The second step, entry of default, “converts the defendant’s admission of liability into a final judgment that terminates the litigation and awards the plaintiff any relief to which the court decides it is entitled, to the extent permitted by Rule 54(c).” Id. Entry of default depends on whether Plaintiff’s allegations establish liability under law. See id. In evaluating a motion for default judgment, the court accepts the plaintiff’s well-pleaded factual allegations as true, except those relating to damages. Maldonado v. Loxton, Inc., 2023 WL 8663464, at *4 (E.D.N.Y. Dec. 15, 2023) (citing Greyhound Exhibitgroup, Inc. v. E.L.U.L. Realty Corp., 973 F.2d 155, 158 (2d Cir. 1992)). “The Court must draw all reasonable inferences in favor of the movant.” Esquivel v. Lima Rest. Corp., 2023 WL 6338666, at *3 (E.D.N.Y. Sept. 29, 2023) (citing Finkel v. Romanowicz, 577 F.3d 79, 84 (2d Cir. 2009)). However, the movant’s factual allegations must be sufficient to state a claim; the Court need not accept legal conclusions couched as facts. See Priestley, 647 F.3d at 506 (citing Ashcroft v.

Iqbal, 556 U.S. 662, 678 (2009)). When liability is established, the movant must “substantiate its claim for damages with evidence to prove the extent of those damages.” Kelly Toys Holdings, LLC v. Airpods Pro Store, 2022 WL 2801077, at *6 (S.D.N.Y. July 18, 2022). DISCUSSION I. ADA Claim To state a claim under the ADA, a plaintiff must allege “(1) [that] he or she is disabled within the meaning of the ADA; (2) that the defendants own, lease, or operate a place of public accommodation; and (3) that the defendants discriminated against the plaintiff within the meaning of the ADA.” Brown v. Good Friend Deli & Tobacco Corp., 2021 WL 2021 WL 5822232, at *5 (S.D.N.Y. Dec. 7, 2021) (citing Roberts v. Royal Atl. Corp., 542 F.3d 363, 368 (2d Cir. 2008)).

The first and third elements of an ADA claim are clearly met. Blindness is a disability covered by the ADA. See 42 U.S.C. § 12102(2)(A). In addition, Defendant has denied Plaintiff the opportunity to benefit from the Website on account of his disability, in violation of the ADA. See 42 U.S.C. § 12182(b)(1)(A)(i). Defendant failed to provide access necessary for Plaintiff, as a blind person, to navigate the Website and purchase the same merchandise on the Website that a seeing person can purchase. Compl. ¶ 36.

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Sumlin v. New York Beer Co., LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sumlin-v-new-york-beer-co-llc-nysd-2025.