ADA Website Lawsuits by State: California, Florida, New York, and Illinois in 2026

Website accessibility litigation isn’t slowing down, it’s accelerating, and it’s increasingly concentrated in four states. If your business serves customers in California, Florida, New York, or Illinois, understanding how each state’s laws work (and why plaintiffs’ firms keep filing there) is the first step toward protecting your business.

Let’s delve into ADA website lawsuits by state, and the next steps you should take.

ADA Website Lawsuits by State: Numbers at a Glance

Digital accessibility litigation has been climbing for years, but 2025 marked a clear rebound after two down years. According to Seyfarth Shaw’s federal court tracking, plaintiffs filed 3,117 website accessibility lawsuits in federal court in 2025, a 27% jump from 2,452 in 2024. Website cases now make up roughly a third of all ADA Title III federal filings.

Layer in state courts, and the picture gets bigger, and shifts geographically. EcomBack’s full-year 2025 litigation report tracked 3,948 combined federal and state website lawsuits for the year, broken out by state as follows:

Together, these four states accounted for roughly 87% of all website accessibility lawsuits filed in the U.S. last year. New York’s volume is falling as its federal courts apply stricter standing requirements, but Illinois is filling the gap fast, with some of the same plaintiffs’ firms simply relocating their filings.

Why These Four States Specifically?

The concentration isn’t random. It comes down to two things: state laws that add monetary damages on top of the federal ADA, and courts that have been receptive to website-as-public-accommodation claims.

The federal Americans with Disabilities Act (Title III) prohibits disability discrimination by “places of public accommodation,” and courts have increasingly read that to include commercial websites.

But Title III itself only allows plaintiffs to seek injunctive relief and attorney’s fees, not cash damages. That’s where state law comes in. California, New York, and Illinois all have their own civil rights statutes that layer monetary damages on top of an ADA violation, which is a major reason plaintiffs’ firms target these states specifically.

California: The Unruh Act Turns ADA Claims Into Cash Claims

California’s Unruh Civil Rights Act (Civil Code §§ 51–52) is the single biggest reason the state remains a top litigation target. Under a 1992 amendment, any violation of the ADA is automatically also a violation of the Unruh Act, and Unruh Act damages are far more generous than what the ADA alone provides.

Per the California Civil Jury Instructions on Unruh Act claims, a prevailing plaintiff can recover actual damages, plus a statutory minimum of $4,000 per violation regardless of provable financial loss, plus attorney’s fees. Because each barrier a visitor encounters can be treated as a separate violation, and each site visit can multiply the count, exposure adds up quickly, which is exactly the financial incentive that has sustained a steady stream of California filings for over a decade.

One notable shift: California’s litigation has moved almost entirely into state court. Federal filings under the ADA specifically for California websites have dropped sharply as plaintiffs’ firms favor the state-court path to Unruh Act damages instead.

Practical takeaway: If your website is used by California residents, you don’t need a physical presence in the state to be sued. The Unruh Act’s damages structure makes California one of the highest-stakes states for even a single unresolved WCAG failure.

Florida: The Fastest-Growing Hotspot In Raw Volume

Florida had the sharpest single-year jump on the list, up 51% year-over-year to 950 lawsuits in 2025, per EcomBack’s data. Florida litigation runs almost entirely through federal court under Title III, since Florida doesn’t have a state statute with the kind of statutory-damages structure California and New York plaintiffs rely on.

That doesn’t make Florida low-risk. It makes it high-volume. Federal filings are relatively inexpensive and fast for plaintiffs’ firms to produce at scale, and Florida-based courts have been a consistently active venue for exactly that kind of high-frequency filing. Restaurant, hospitality, and retail businesses with a Florida customer base have been especially exposed.

New York: Two Extra Layers of State and City Law

New York’s total filings dropped from 1,600 in 2024 to 1,108 in 2025, still the largest single-state total, but the decline reflects a real legal shift.

As the New York State Bar Association has documented, courts have long treated “places of public accommodation” as extending beyond physical locations to cover websites. A hotel’s booking site was found to trigger the same access obligations as its front desk in one representative case. But federal courts in New York have recently tightened standing requirements, making it harder for a plaintiff to simply allege an ADA violation and proceed.

That’s pushed plaintiffs toward New York’s own statutes instead: the New York State Human Rights Law and the New York City Human Rights Law. The NYC Commission on Human Rights enforces the city-level law, which, like the state law, reaches any business serving New York City residents regardless of where that business is physically located. Both New York statutes allow for damages that the federal ADA does not, which is why so much New York litigation has migrated from federal to state court even as overall filings dip.

Practical takeaway: New York’s declining federal numbers don’t mean declining risk. They mean the same litigation pressure has moved to state and city courts, where plaintiffs have more legal tools and a lower bar to clear.

Illinois: The Fastest-Rising State In the Country

Illinois is the story of 2025 and 2026. Filings rose from 92 in 2024 to 576 in 2025, a more than five-fold increase, and Seyfarth Shaw’s tracking shows Illinois climbing to fourth place nationally in federal filings, passing longtime litigation states like Minnesota and Pennsylvania in the process.

Seyfarth’s analysis attributes much of the surge to “some of the most prolific New York plaintiffs’ lawyers” moving their filing activity into Illinois.

The underlying legal hook is similar to California’s: the Illinois Human Rights Act, enforced by the Illinois Department of Human Rights, prohibits discrimination in the “full and equal enjoyment” of facilities and services by any place of public accommodation. As with New York and California, plaintiffs’ firms have applied that language to commercial websites, and Illinois courts have so far been a receptive venue.

Practical takeaway: Illinois moved from a minor player to a top-four litigation state in a single year. If your compliance priorities were set based on older lawsuit-volume data, Illinois may now deserve the same attention you’re giving California, Florida, and New York.

What’s Actually Triggering These Lawsuits?

Regardless of state, the underlying accessibility failures tend to be the same handful of issues, repeated across thousands of complaints.

The most common WCAG 2.1 failures cited in litigation are low-contrast text, missing image alt text, unlabeled form fields, empty links, empty buttons, and missing document-language declarations. These are foundational, code-level issues, not edge cases, which is part of why serial plaintiffs can identify them quickly on almost any given site.

The Title II Deadline: A Wrinkle for Public Entities and Their Vendors

If your organization is a state or local government entity, or a private company that contracts with one, note that the timeline recently changed.

The Department of Justice’s 2024 Title II rule originally set an April 24, 2026 WCAG 2.1 AA compliance deadline for public entities serving 50,000 or more residents. On April 20, 2026, the DOJ issued an interim final rule extending that deadline to April 26, 2027 for larger entities and April 26, 2028 for smaller entities and special districts.

The substantive WCAG 2.1 AA requirement is unchanged. Only the deadline moved. This extension doesn’t affect private-business Title III litigation, which continues to proceed under the existing case law described above.

Where to Go From Here

The pattern across all four states is consistent: courts treat websites as places of public accommodation, state laws add real monetary stakes on top of the federal ADA, and a relatively small number of plaintiffs’ firms drive most of the filings by identifying the same handful of common WCAG failures.

Regardless of whether your business is based in one of these states or simply serves customers there, the strongest defense is the same one regardless of jurisdiction: a genuine, code-level accessibility audit and remediation plan.

This article is for informational purposes only and does not constitute legal advice. Consult a qualified attorney for guidance specific to your business.

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