Robles v. Domino’s Pizza
United States Court of Appeals for the Ninth Circuit
913 F.3d 898 (2019)
Domino’s Pizza, LLC (Domino’s) (defendant) created and maintained a website and phone application that allowed customers to order food for delivery or in-store pickup. Guillermo Robles (plaintiff) was a blind Domino’s customer who used screen-reading software to access Internet content. Robles attempted multiple times to order pizza from a nearby store through the Domino’s website, but the website was not compatible with Robles’s screen-reading software. Robles filed suit in federal district court against Domino’s for violating the Americans with Disabilities Act (ADA) by failing to design and operate its website to be fully accessible for blind or visually impaired customers. Robles sought damages and an injunction forcing Domino’s to follow private industry standards for website accessibility. Domino’s moved for summary judgment, arguing that the ADA did not apply to its website or application and that applying the ADA violated the company’s due-process rights. Domino’s alternatively invoked the primary-jurisdiction doctrine, asking the court to dismiss the case until the Department of Justice (DOJ) could issue technical regulations for website-accessibility standards under the ADA. The district court granted summary judgment in favor of Domino’s, finding that because the DOJ had not issued specific technical standards, the court needed to invoke the primary-jurisdiction doctrine to avoid due-process concerns. Robles appealed to the Ninth Circuit. The court found that the ADA did apply to the Domino’s website and application because the services facilitated customers’ access to the goods of the physical stores, which were places of public accommodation. The court then addressed due process and primary jurisdiction.
Rule of Law
Holding and Reasoning (Owens, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 707,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 707,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 44,500 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.