Camacho v. Northeastern University

Northeastern, with its main campus in Boston, Massachusetts, participated in a college fair in Manhattan. Later that same month, it was served with a complaint alleging that a blind New Yorker, Jason Camacho, had attended that fair, gone to Northeastern’s website, and run into several web-design-based barriers that prevented him from accessing information through his screen-reader software. Northeastern now moves this Court to dismiss Camacho’s amended complaint because the Court does not have personal jurisdiction over it and because Camacho has failed to allege injury sufficient to convey standing. The Court finds that it does not have personal jurisdiction and, on that basis, GRANTS Northeastern’s motion.¹ I. BACKGROUND Northeastern University is a post-secondary school chartered under the laws of the Commonwealth of Massachusetts and with a main campus in Boston. Decl. of Alysa Gerlach (“Gerlach Dep.”) 3, Doc. 23. It has no offices, bank accounts, or other physical presence in New York. Id. 4-6. As part of its recruiting efforts, its admissions team travels the country to visit prospective students. In 2018, the team collectively attended over 1000 admission events. Decl. of Elizabeth Cheron (“Cheron Decl.”) 3, Doc. 22. One of these events was a college fair that took place at the Javits Center in New York City in November 2018. Decl. of Jon Bernstein (“Bernstein Decl.”) 3, Doc. 21. Jason Camacho attended that fair, as well. First Amended Compl. (“Compl.”) 33, Doc. 15. Camacho is a blind resident of Brooklyn, New York. Id. 20. He currently attends the Catholic Guild for the Blind and avers that he intends to attend a four-year college to obtain a bachelor’s degree. Decl. of Jason Camacho (“Camacho Decl.”)

4, 5, Doc. 28. While at the fair, he spoke “to representatives of several colleges,” but, finding that the information they offered was “limited,” he left. Id. 8. He does not allege that he spoke with anyone representing Northeastern College, and neither Northeastern’s records nor the people staffing Northeastern’s table suggest he, or any visually impaired person, approached the table that day. Bernstein Decl.