2026 Mid-Year ADA Website Lawsuit Report
Filings Hold Steady Nationally While the Map Redraws Itself: Illinois Takes the Lead, New York Falls to Third
From January through June 2026, U.S. courts recorded 2,045 ADA website accessibility lawsuits — a 1.54% increase over the 2,014 filed in the same period of 2025. The national total barely moved. Almost everything underneath it did.
Executive Summary
Filings Remain Historically Elevated
2,045 lawsuits in six months works out to more than 11 new cases every day, holding at the record level set in 2025 rather than retreating from it.
The Geography Reshuffled Completely
Illinois took first place for the first time with 463 filings (+95.36%), while New York — the leading state for years — dropped 238 cases (−37.36%) to third. Indiana was the fastest-growing state in the country, up 275% from 28 filings to 105.
Litigation Also Spread Out
The top state accounted for 22.64% of filings, down from 31.63% a year earlier, and the top three states fell from 74.7% to 62.9% of the national total. Concentration by state is loosening even as the overall volume holds.
Repeat Filers Tightened Their Grip
225 plaintiffs filed all 2,045 lawsuits, up from 188 in 2025 — yet just 30 of them filed more than half (1,035 cases, 50.61%), and 10 law firms filed 80.59%. Both figures are higher than a year ago.
Shopify Overtook Custom-Coded Sites as the Most-Targeted Platform
Shopify-based websites drew 952 lawsuits (46.55%), up from 653 (32.42%) in 2025, while WordPress fell from 403 to 265.
Accessibility Widgets Still Did Not Prevent Lawsuits
496 lawsuits (24.25%) targeted websites that already had a widget or overlay installed — up 38 cases on 2025, and a larger share of the total than last year.
State-Wise ADA Website Lawsuits Filed
Lawsuits are still packed into a handful of states, but the order at the top has changed substantially. Illinois nearly doubled its 2025 total to lead the country, while New York — the usual number one — fell sharply to third place behind California.
State-Wise Comparison : Mid-Year 2026 vs. Mid-Year 2025
| State | Mid-Year 2026 | Mid-Year 2025 | Percentage | Up / Down |
|---|---|---|---|---|
| Illinois | 463 | 237 | 22.64% | +95.36% |
| California | 424 | 380 | 20.73% | +11.58% |
| New York | 399 | 637 | 19.51% | −37.36% |
| Florida | 333 | 487 | 16.28% | −31.62% |
| Minnesota | 120 | 84 | 5.87% | +42.86% |
| Indiana | 105 | 28 | 5.13% | +275.00% |
| Pennsylvania | 62 | 47 | 3.03% | +31.91% |
| All Other States | 139 | 114 | 6.80% | +21.93% |
| Total ADA Lawsuits Filed | 2,045 | 2,014 | 100.00% | +1.54% |
Note on the 2025 baseline: the 2025 mid-year report broke out Missouri (48) separately and counted Indiana within All Other States. The 2025 column above has been recast to match the 2026 categories, moving Missouri into All Other States and separating Indiana, so the two years compare on a like-for-like basis.
State wise Monthly Breakdown
| State | Total | Percentage | Jan | Feb | Mar | Apr | May | Jun |
|---|---|---|---|---|---|---|---|---|
| Illinois | 463 | 22.64% | 60 | 85 | 112 | 81 | 96 | 29 |
| California | 424 | 20.73% | 73 | 70 | 78 | 82 | 66 | 55 |
| New York | 399 | 19.51% | 67 | 55 | 63 | 59 | 70 | 85 |
| Florida | 333 | 16.28% | 88 | 47 | 51 | 44 | 54 | 49 |
| Minnesota | 120 | 5.87% | 18 | 30 | 24 | 13 | 19 | 16 |
| Indiana | 105 | 5.13% | 13 | 23 | 20 | 28 | 16 | 5 |
| Pennsylvania | 62 | 3.03% | 21 | 0 | 0 | 0 | 1 | 40 |
| All Other States | 139 | 6.80% | 25 | 24 | 43 | 27 | 13 | 7 |
| Total | 2,045 | 100.00% | 365 | 334 | 391 | 334 | 335 | 286 |
Illinois was the story of the half-year. Filings nearly doubled from 237 to 463 (+95.36%), taking the top spot for the first time and making the state the single largest venue for ADA website litigation at 22.64% of all filings. Its momentum was concentrated in the first five months — 60, 85, 112, 81 and 96 — before dropping to 29 in June.
New York recorded the largest decline of any state, falling from 637 filings to 399 — a loss of 238 cases, or 37.36%. After years as the country’s most litigious state for website accessibility, it now sits third. Notably, its monthly trend runs the opposite way to Illinois: New York was the only leading state to finish the half-year on its strongest month, with 85 filings in June.
California moved up to second place with 424 filings (+11.58%), a moderate increase on 380 in 2025 and the steadiest month-to-month distribution of any major state. Florida continued its pullback, dropping 31.62% from 487 to 333 and falling from second place to fourth.
Indiana was the fastest-growing state in the country by a wide margin, jumping from 28 filings to 105 (+275%) and arriving as the sixth most active state almost from nowhere. Minnesota grew 42.86% from 84 to 120, holding its position as the most active state outside the traditional leaders.
Pennsylvania rose 31.91% from 47 to 62, but its court count consistently understates the real pressure in the state. Demand letters are especially common there and never appear in filing totals. Its monthly pattern — 21 filings in January, nothing at all from February through April, then 40 in June — reflects a small number of filers working in concentrated bursts rather than a steady stream, the same lumpy pattern the state showed in 2025.
All Other States grew 21.93% from 114 to 139, confirming that litigation continued to reach beyond the established hotspots.
Key Summary Points
The flat national total is misleading. Filings rose just 1.54% overall, but four of the eight tracked jurisdictions moved by more than 30% and two moved by more than 90%. The stability is in the aggregate only.
Illinois replaced New York at the top. Illinois climbed from fourth place to first (237 to 463); New York fell from first to third (637 to 399). California moved from third to second, and Florida from second to fourth.
New York’s 238-case decline was the largest single drop of any state and the main counterweight to growth elsewhere. Had New York simply held its 2025 level, the national total would have risen 13.4% rather than 1.54%.
Litigation is dispersing geographically. The leading state’s share of filings fell from 31.63% to 22.64%, and the top three states fell from 74.7% of the national total to 62.9%. Indiana’s +275% and All Other States’ +21.93% point the same direction.
Indiana is the new entrant to watch. A state that produced 28 filings in the first half of 2025 produced 105 in the first half of 2026, overtaking Pennsylvania and closing on Minnesota.
June was the quietest month in both years. Filings fell to 286 in June 2026 from 335 in May, mirroring 2025 (289 in June against 388 in May). Part of this reflects a genuine seasonal pattern; part reflects activity moving into demand letters and state courts, neither of which appears in these counts.
Only 30 Plaintiffs Filed More Than Half of All ADA Website Lawsuits
From January to June 2026, 225 different plaintiffs filed 2,045 lawsuits — up from 188 plaintiffs a year earlier, an increase of 19.68%. More people are filing. That has not made the field any less concentrated.
Just 30 plaintiffs filed 1,035 lawsuits, or 50.61% of everything. A year earlier it took 31 plaintiffs to pass the same halfway mark, at 50.45%. And at every comparable measure, concentration rose: the top five plaintiffs went from 17.03% to 21.52% of all filings, and the top ten from 26.66% to 29.98%.
| No. | Plaintiff Name | Firm Name | Total | Percentage | Jan | Feb | Mar | Apr | May | Jun |
|---|---|---|---|---|---|---|---|---|---|---|
| 1 | Michael Sandoval | Manning Law, APC | 166 | 8.12% | 19 | 18 | 20 | 40 | 36 | 33 |
| 2 | Julie Dalton | Throndset Michenfelder, LLC | 104 | 5.09% | 16 | 29 | 22 | 10 | 13 | 14 |
| 3 | Perla Mageno | Manning Law, APC | 71 | 3.47% | 26 | 12 | 7 | 11 | 11 | 4 |
| 4 | Jesus Torres | Manning Law, APC | 55 | 2.69% | 3 | 15 | 18 | 12 | 5 | 2 |
| 5 | Nestor A Proveyer | Adams & Associates, P.A. | 44 | 2.15% | 11 | 8 | 4 | 4 | 11 | 6 |
| 6 | Blair Douglass | East End Trial Group LLC | 43 | 2.10% | 21 | 0 | 0 | 0 | 1 | 21 |
| 7 | Livingston Bennett | Equal Access Law Group, PLLC | 35 | 1.71% | 4 | 8 | 13 | 2 | 8 | 0 |
| 8 | Nicholas Pagan | Alberto R. Leal, Esq., P.A. | 35 | 1.71% | 0 | 4 | 7 | 5 | 11 | 8 |
| 9 | Norma O. Gazonni | Brasil & Brasil, P.A | 32 | 1.56% | 8 | 4 | 5 | 4 | 6 | 5 |
| 10 | Alvear Enrique | Roderick V. Hannah, Esq., P.A. | 28 | 1.37% | 3 | 3 | 9 | 2 | 10 | 1 |
| 11 | Howard Wilson | Stein Saks, PLLC | 26 | 1.27% | 4 | 5 | 5 | 0 | 5 | 7 |
| 12 | Arantza Castro | Mendez Law Offices, PLLC | 25 | 1.22% | 6 | 1 | 9 | 3 | 1 | 5 |
| 13 | Rosemarie Ramirez | Stein Saks, PLLC | 25 | 1.22% | 0 | 5 | 8 | 0 | 5 | 7 |
| 14 | Aaron See | Equal Access Law Group, PLLC | 24 | 1.17% | 5 | 5 | 3 | 7 | 3 | 1 |
| 15 | James Murphy | Gottlieb & Associates | 23 | 1.12% | 14 | 0 | 0 | 0 | 9 | 0 |
| 16 | Andre Battle | Horowitz Law, PLLC | 23 | 1.12% | 2 | 3 | 5 | 4 | 7 | 2 |
| 17 | Lisa Anderson | Equal Access Law Group, PLLC | 23 | 1.12% | 6 | 8 | 3 | 4 | 2 | 0 |
| 18 | Jennifer Carbine | Manning Law, APC | 21 | 1.03% | 7 | 2 | 2 | 6 | 1 | 3 |
| 19 | Hernandez Rebecca | Manning Law, APC | 21 | 1.03% | 6 | 5 | 2 | 1 | 2 | 5 |
| 20 | Morgan Cole | Equal Access Law Group, PLLC | 21 | 1.03% | 2 | 9 | 2 | 5 | 2 | 1 |
| 21 | Kevin Orcel | Stein Saks, PLLC | 21 | 1.03% | 0 | 8 | 5 | 6 | 2 | 0 |
| 22 | Cedric Bishop | Gottlieb & Associates | 20 | 0.98% | 0 | 3 | 1 | 7 | 0 | 9 |
| 23 | Biglang-Awa-Castro Sheila | Manning Law, APC | 20 | 0.98% | 0 | 2 | 2 | 3 | 6 | 7 |
| 24 | Sandra Ford | Equal Access Law Group, PLLC | 19 | 0.93% | 2 | 3 | 1 | 8 | 4 | 1 |
| 25 | Geovanni Bahena Figueroa | Stein Saks, PLLC | 19 | 0.93% | 8 | 5 | 6 | 0 | 0 | 0 |
| 26 | Mary Ann Deinnocentes | Equal Access Law Group, PLLC | 19 | 0.93% | 0 | 7 | 3 | 8 | 1 | 0 |
| 27 | Victor Lopez | Gottlieb & Associates | 19 | 0.93% | 0 | 0 | 8 | 1 | 6 | 4 |
| 28 | Nelson Fernandez | Roderick V. Hannah, Esq., P.A. | 18 | 0.88% | 13 | 0 | 0 | 3 | 1 | 1 |
| 29 | Milagros Senior | Gottlieb & Associates | 18 | 0.88% | 0 | 0 | 5 | 3 | 2 | 8 |
| 30 | Alejandro Espinoza | Mendez Law Offices, PLLC | 17 | 0.83% | 4 | 1 | 5 | 2 | 2 | 3 |
| 30 plaintiffs filed 50.61% of ADA lawsuits in mid-year 2026 | 1,035 | 50.61% | 190 | 173 | 180 | 161 | 173 | 158 | ||
| 195 plaintiffs collectively filed 49.39% of ADA lawsuits in mid-year 2026 | 1,010 | 49.39% | 175 | 161 | 211 | 173 | 162 | 128 | ||
| 225 plaintiffs filed 2,045 website ADA lawsuits in mid-year 2026 | 2,045 | 100.00% | 365 | 334 | 391 | 334 | 335 | 286 | ||
Plaintiff Concentration, 2026 vs 2025
The 2025 mid-year report reported concentration at the Top 5, 10, 20 and 50 marks. Only the Top 5 and Top 10 tiers compare directly; the Top 31 comparison uses the 2025 report’s own 31-plaintiff threshold, and no 2025 equivalent exists for the Top 81.
Key Summary Points
More plaintiffs, tighter concentration. The plaintiff pool grew 19.68% to 225 people, but the share held by the busiest filers rose at every measurable tier. Growth at the edges did not dilute the centre.
Michael Sandoval (Manning Law, APC) remained the single most active plaintiff by a wide margin, filing 166 lawsuits (8.12%) — up from 114 in 2025, a 45.6% increase. One individual accounts for roughly one in every twelve ADA website lawsuits filed nationally.
Julie Dalton (Throndset Michenfelder, LLC) ranked second with 104 lawsuits (5.09%), up from 74, and Perla Mageno (Manning Law, APC) third with 71 (3.47%), up from 55. All three of the top plaintiffs increased their volume year over year.
The top five is where the growth sits. Those five plaintiffs filed 440 lawsuits between them, against 343 for the top five in 2025 — a 28% increase in a group of the same size.
Two firms build volume in opposite ways. Six of the top 30 plaintiffs file under Manning Law, and those six account for 354 of the firm’s 366 cases — almost its entire output. Equal Access Law Group also placed six plaintiffs in the top 30, but they account for only 141 of its 526 cases, meaning the bulk of its volume comes from filers outside the top 30 entirely.
Filing patterns are bursty, not steady. Several high-volume plaintiffs recorded whole months at zero — Blair Douglass filed 21 in January, nothing for three months, then 21 in June; James Murphy filed 14 in January and 9 in May, and nothing in the other four months. Monthly totals should not be read as a measure of any individual’s ongoing activity.
Only 10 Law Firms Filed More Than 80% of ADA Website Lawsuits
Firm-level concentration is the most stable feature of this litigation, and in 2026 it intensified. Of 2,045 lawsuits filed, 10 firms accounted for 1,648 — 80.59% of the national total, up from 77.41% a year earlier. Thirty-two firms filed at least one case; five of them filed nearly two-thirds of everything.
| No. | Plaintiff Law Firm | Total | Percentage | Jan | Feb | Mar | Apr | May | Jun |
|---|---|---|---|---|---|---|---|---|---|
| 1 | Equal Access Law Group, PLLC | 526 | 25.72% | 82 | 105 | 112 | 114 | 92 | 21 |
| 2 | Manning Law, APC | 366 | 17.90% | 62 | 55 | 55 | 75 | 64 | 55 |
| 3 | Gottlieb & Associates | 197 | 9.63% | 39 | 24 | 28 | 30 | 37 | 39 |
| 4 | Stein Saks, PLLC | 124 | 6.06% | 15 | 24 | 41 | 6 | 15 | 23 |
| 5 | Throndset Michenfelder, LLC | 120 | 5.87% | 18 | 30 | 24 | 13 | 19 | 16 |
| 6 | Joseph & Norinsberg, LLC | 73 | 3.57% | 10 | 10 | 13 | 8 | 16 | 16 |
| 7 | Roderick V. Hannah, Esq., P.A. | 67 | 3.28% | 24 | 8 | 13 | 7 | 11 | 4 |
| 8 | NYE Stirling, Hale & Miller, LLP | 64 | 3.13% | 6 | 12 | 10 | 12 | 5 | 19 |
| 9 | AJG Law Group, PC | 56 | 2.74% | 11 | 15 | 21 | 7 | 2 | 0 |
| 10 | Adams & Associates, P.A. | 55 | 2.69% | 13 | 8 | 4 | 6 | 15 | 9 |
| 10 law firms filed 80.59% of ADA lawsuits | 1,648 | 80.59% | 280 | 291 | 321 | 278 | 276 | 202 | |
| 22 law firms filed 19.41% of ADA lawsuits | 397 | 19.41% | 85 | 43 | 70 | 56 | 59 | 84 | |
| 32 law firms collectively filed 2,045 lawsuits | 2,045 | 100.00% | 365 | 334 | 391 | 334 | 335 | 286 | |
Firm Concentration and Year-Over-Year Movement
Equal Access Law Group, PLLC led the country by a wide margin with 526 lawsuits (25.72%) — more than a quarter of every ADA website case filed nationally, and more than double its 248 filings in 2025. Its pace was relentless from January through May (82, 105, 112, 114, 92) before dropping to 21 in June.
That June drop deserves context rather than alarm. The firm showed exactly the same shape in 2025, when it filed 65 cases in May and 17 in June. A collapse that repeats in consecutive years is a pattern, not an anomaly — and the most likely explanation is that activity moves into demand letters and state-court filings, neither of which appears in these counts. If so, the firm’s real June volume is higher than the public docket shows.
Manning Law, APC placed second with 366 lawsuits (17.90%), up from 287, and was the most consistent high-volume filer in the dataset — never below 55 cases in any month. Together, Equal Access and Manning Law accounted for 43.62% of all ADA website litigation in the first half of 2026.
The more revealing story is at the other end of the top ten. Five of the ten leading firms filed fewer cases than in 2025: Gottlieb & Associates fell from 265 to 197, Stein Saks from 211 to 124, Roderick V. Hannah from 137 to 67, NYE Stirling from 99 to 64, and AJG Law Group from 72 to 56. Two firms that ranked in the 2025 top ten — Aleksandra Kravets, Esq. P.A. (89) and Asher Cohen PLLC (67) — dropped out of the leading group altogether.
Joseph & Norinsberg, LLC entered the top ten with 73 lawsuits (3.57%), and Adams & Associates, P.A. grew from 36 to 55 (+52.8%). Throndset Michenfelder, LLC rose from 84 to 120 (+42.9%), driven almost entirely by Julie Dalton’s Minnesota filings.
Key Summary Points
Concentration rose at every tier. Top 5 firms went from 57.00% to 65.18% of all filings, top 10 from 77.41% to 80.59%, top 15 from 88.78% to 91.10% — even though the number of firms filing grew from 30 to 32.
One firm now files a quarter of everything. Equal Access Law Group more than doubled its volume, from 248 to 526 lawsuits, and alone accounts for 25.72% of the national total.
The rise is a redistribution, not a broad expansion. Equal Access and Manning Law added 357 cases between them, while five other top-ten firms shed 276. The national total barely moved because gains at the top offset losses immediately below.
The plaintiff-firm relationship differs sharply by firm. Manning Law concentrates almost its entire output in six named repeat plaintiffs; Equal Access spreads 526 cases across a far wider roster, with only 141 attributable to its six top-30 filers.
Court counts understate total legal pressure. Demand letters never enter public records, and firms filing in state courts are harder to track than those in federal court. The 2,045 figure is a floor, not a ceiling.
Eight Industries Faced More Than 92% of All Lawsuits
ADA website litigation remains firmly focused on consumer-facing sectors. Of 2,045 lawsuits filed, eight industries accounted for 1,897 — 92.76% of the total, with the remaining seven categories sharing just 148 cases between them.
| No. | Industry Category | Total | Percentage | Jan | Feb | Mar | Apr | May | Jun |
|---|---|---|---|---|---|---|---|---|---|
| 1 | Restaurant, Food, Drinks & Beverages | 593 | 29.00% | 128 | 108 | 120 | 105 | 74 | 58 |
| 2 | Lifestyle, Fashion, Clothing & Apparel | 565 | 27.63% | 80 | 95 | 102 | 75 | 113 | 100 |
| 3 | Health, Beauty & Wellness | 308 | 15.06% | 63 | 39 | 55 | 50 | 57 | 44 |
| 4 | Home, Furniture & Garden | 206 | 10.07% | 33 | 34 | 40 | 35 | 29 | 35 |
| 5 | Retail & Consumer Goods | 74 | 3.62% | 16 | 15 | 15 | 13 | 12 | 3 |
| 6 | Fitness & Sports Accessories | 60 | 2.93% | 13 | 7 | 6 | 12 | 9 | 13 |
| 7 | Automotive, Tools & Equipment | 46 | 2.25% | 5 | 5 | 12 | 9 | 8 | 7 |
| 8 | Computer, Mobile & Electronic Accessories | 45 | 2.20% | 5 | 6 | 11 | 11 | 8 | 4 |
| 8 industries faced 92.76% of lawsuits | 1,897 | 92.76% | 343 | 309 | 361 | 310 | 310 | 264 | |
| 7 industries faced 7.24% of lawsuits | 148 | 7.24% | 22 | 25 | 30 | 24 | 25 | 22 | |
| Total ADA website lawsuits by industry | 2,045 | 100.00% | 365 | 334 | 391 | 334 | 335 | 286 | |
Restaurant, Food, Drinks & Beverages remained the most targeted sector with 593 lawsuits (29.00%). Menu-driven websites, online ordering systems and third-party reservation and delivery integrations create a high density of interactive elements, and accessibility failures in any one of them can block a customer from completing an order.
Lifestyle, Fashion, Clothing & Apparel followed closely with 565 lawsuits (27.63%). Together, these two sectors accounted for 1,158 cases — 56.63% of all ADA website litigation. Two industries, more than half the national total.
The two also moved in opposite directions across the half-year. Restaurant filings declined steadily from 128 in January to 58 in June, while apparel filings climbed to 113 in May and 100 in June — making apparel the most-targeted sector in the second quarter even though restaurants led for the period overall.
Health, Beauty & Wellness ranked third with 308 lawsuits (15.06%) and Home, Furniture & Garden fourth with 206 (10.07%). Below them, Retail & Consumer Goods (74), Fitness & Sports Accessories (60), Automotive, Tools & Equipment (46) and Computer, Mobile & Electronic Accessories (45) each drew meaningful volume, confirming that no consumer-facing category is too small or too specialised to be targeted.
A Note on Year-Over-Year Industry Comparison
The industry taxonomy was consolidated for 2026, moving from 21 categories to 15. Several 2026 categories combine sectors that were counted separately in 2025 — Health, Beauty & Wellness, for example, covers ground previously split between Beauty, Skin & Body Care and Medical & Health. A full year-over-year comparison is therefore not possible on a like-for-like basis. Four categories carry identical definitions in both years and can be compared directly:
Key Summary Points
Industry concentration increased. The leading sectors accounted for 92.76% of filings in 2026 against 90.62% for the top ten categories in 2025 — litigation narrowed onto fewer industries even as it spread across more states.
Two sectors carry more than half the risk. Restaurant, Food, Drinks & Beverages (29.00%) and Lifestyle, Fashion, Clothing & Apparel (27.63%) together account for 56.63% of all filings, a pattern unchanged from 2025.
Both leading sectors declined slightly in absolute terms — restaurants by 21 cases, apparel by 15 — meaning their continued dominance reflects the shape of the litigation rather than growth in those industries specifically.
Apparel overtook restaurants in the second quarter. Restaurant filings fell from 128 in January to 58 in June while apparel rose to 113 in May and 100 in June, a crossover worth watching into the second half of the year.
Smaller categories are growing fastest in percentage terms. Fitness & Sports Accessories rose 17.6% and Computer, Mobile & Electronic Accessories 21.6% — small bases, but the direction is consistent with litigation reaching further down the long tail.
24.25% of ADA Lawsuits Targeted Sites Using Accessibility Widgets
Accessibility widgets and overlays are marketed as a fast route to ADA compliance. The filing data does not support that claim. During the first half of 2026, 496 ADA website lawsuits — 24.25% of the national total — were filed against websites that already had an accessibility widget installed. That is up from 458 in the same period of 2025, an increase of 38 cases (+8.30%), and it represents a larger share of all filings than a year earlier (22.74%).
Put plainly: nearly one in four ADA website lawsuits in 2026 targeted businesses that had already invested in an accessibility tool intended to help prevent such lawsuits.
The half-year splits cleanly in two. Across the first quarter, widget-related filings ran far ahead of 2025 — 276 against 209, a 32.1% increase — with March alone up 54%. The second quarter reversed: 220 against 249, an 11.6% decline. The annual increase is real, but it was earned entirely in the first three months.
The pattern matters because it undercuts the most common defence of these tools, which is that lawsuits against widget users reflect early or poorly configured installations that later improve. If that were the driver, the trend would move consistently in one direction. Instead the year-over-year gap swung 43 percentage points between the first and second quarters, which points to variation in filing behaviour rather than to changes in how well widgets work.
Regulators Have Reached the Same Conclusion
The legal risk is no longer the only exposure. In 2025 the Federal Trade Commission reached a $1 million settlement with AccessiBe, one of the largest widget vendors, over marketing that presented its overlay as a guaranteed route to ADA compliance while critical barriers remained in place for users with disabilities. Businesses relying on a widget alone now face potential regulatory scrutiny alongside private litigation. Read our analysis of the FTC settlement with AccessiBe.
Key Summary Points
496 lawsuits (24.25% of all filings) targeted websites with an accessibility widget installed, up from 458 (22.74%) in the first half of 2025.
Widget-equipped sites grew as a share of the total, meaning they were sued at a slightly higher relative rate in 2026 than in 2025 — the opposite of what would be expected if these tools reduced exposure.
The increase was front-loaded. Q1 2026 ran 32.1% ahead of Q1 2025; Q2 2026 ran 11.6% behind Q2 2025. Treat the annual figure as a first-quarter effect rather than a steady trend.
An overlay does not remediate the underlying code. Widgets sit on top of a website and adjust presentation at run time. They do not fix missing alternative text, unlabelled form fields, keyboard traps or broken heading structure — the barriers most frequently cited in these complaints.
Regulatory risk now compounds litigation risk, following the FTC’s $1 million settlement with AccessiBe over compliance claims made for its overlay product.
ADA Lawsuits by Website Platform
The most significant platform shift in several years occurred in the first half of 2026: Shopify overtook custom-coded websites to become the most-targeted platform, and it did so decisively. Shopify-based sites drew 952 lawsuits (46.55%), up from 653 (32.42%) a year earlier — a 45.8% increase that lifted the platform from just under a third of all filings to nearly half.
Two platforms now carry 78.87% of all ADA website litigation between them: Shopify and custom-coded sites. WordPress moved in the opposite direction, falling from 403 lawsuits to 265 (−34.2%) and from a fifth of all filings to an eighth. Magento more than halved, from 113 to 52.
None of this indicates that one platform is inherently less accessible than another. It reflects where commerce is being conducted and where plaintiffs are looking. A platform provides the framework; accessibility depends on the theme, the apps installed on top of it, the content the merchant publishes and the checkout flow the customer has to complete. Responsibility for compliance rests with the website owner, not the platform vendor.
Shopify
A leading e-commerce platform that enables businesses to build, manage, and scale online stores through flexible features, customizable storefronts, and intuitive management tools.
Other / Custom-Coded Websites
Custom-designed websites created to deliver unique business requirements through personalized functionality and user experiences.
WordPress
A widely used content management system recognized for its powerful customization options and extensive ecosystem of themes, plugins, and third-party integrations.
Squarespace
A user-friendly website-building platform that enables businesses to design, manage, and maintain professional websites with built-in tools.
Magento
An open-source e-commerce platform, now offered commercially as Adobe Commerce, built for businesses that need extensive customization, large or complex catalogs, and direct control over storefront architecture.
Wix
A drag-and-drop website builder that lets businesses design, publish, and manage sites through visual editing tools and pre-built templates without writing code.
Key Summary Points
Shopify is now the most-targeted platform, with 952 lawsuits (46.55%) against 653 (32.42%) in 2025 — a 45.8% increase and the first time it has led this ranking.
Custom-coded sites fell to second place with 661 lawsuits (32.32%), down slightly from 691, having led the 2025 ranking.
WordPress dropped sharply, from 403 lawsuits (20.01%) to 265 (12.96%), and Magento more than halved, from 113 to 52.
Two platforms carry nearly four-fifths of all risk. Shopify and custom-coded sites together account for 78.87% of ADA website litigation.
Accessibility Depends on Implementation — Not Just the Platform. Accessibility depends on how a website is implemented including its theme, apps, content, and checkout experience rather than the underlying technology.
Most Common Reasons for ADA Website Lawsuits
Despite rising awareness of digital accessibility and clearer legal expectations, most complaints continue to cite the same small set of failures. The barriers below appeared most frequently in ADA website lawsuits filed during the first half of 2026.
Missing or Inaccurate Alternative Text
Images without meaningful alternative text remain one of the most common issues cited, preventing screen reader users from understanding product photos, menus, promotional graphics and other essential visual content.
Inaccessible Forms and Checkout Flows
Forms, checkout processes and account registration pages frequently lack proper labels, instructions or error identification, leaving users who rely on assistive technology unable to complete a purchase or contact the business.
Keyboard Accessibility Failures
Menus, dialogs, pop-ups and interactive controls that cannot be operated with a keyboard alone remain widespread, blocking access for anyone who does not use a mouse.
Missing or Weak Focus Indicators
Without a visible indicator showing where keyboard focus currently sits, users cannot track their position on the page, making navigation confusing and error-prone.
Insufficient Color Contrast
Low contrast between text and background continues to be one of the most frequently reported WCAG failures, making content difficult or impossible to read for users with low vision.
Missing ARIA Labels and Semantic Structure
Improper use of ARIA attributes and non-semantic HTML reduces compatibility with screen readers, leaving page structure and controls difficult to interpret.
Improper Heading Hierarchy
Missing, skipped or incorrectly nested headings create navigation barriers for screen reader users, particularly on large content-rich pages and product catalogs.
Inaccessible PDFs and Downloadable Documents
Downloadable menus, catalogs, brochures and forms often lack proper tagging, reading order or document structure, making them unreadable by assistive technology.
Inaccessible Pop-ups and Overlays
Cookie banners, promotional pop-ups, chat widgets and modal dialogs frequently fail to manage focus or provide accessible controls, preventing users from interacting with or dismissing them independently.
Digital Accessibility Trends: 2026 Snapshot
Governments and regulators continued to expand accessibility requirements through the first half of 2026, reshaping compliance expectations well beyond private litigation.
DOJ Extends Title II Deadline: More Time,
Not Less Responsibility
The U.S. Department of Justice has extended the ADA Title II digital accessibility compliance deadlines by one year, to April 26, 2027 for larger public entities and April 26, 2028 for smaller jurisdictions. Only the deadlines moved. The substantive requirement to meet WCAG 2.1 Level AA is unchanged.
The extension gives state and local governments additional time to remediate websites, mobile apps, online forms and digital documents. The practical value of that time depends on how it is used: building a sustainable accessibility programme with auditing, remediation, testing, staff training and ongoing monitoring produces durable compliance, while deferring the work simply relocates the same deadline pressure a year forward.
Court Demands Proof of Accessibility Remediation
A recent ruling in Natosha Dunston v. 243 Dekalb Ave. LLC highlights increased judicial scrutiny of ADA settlements. The court required the plaintiff to provide proof that agreed accessibility improvements had actually been completed before enforcing the attorneys’ fee portion of the settlement.
The decision emphasizes that ADA litigation should result in meaningful accessibility improvements, not simply financial settlements. It also signals that courts may increasingly examine whether remediation promised in ADA cases is actually completed.
Find out more about this case: Stunning ADA Ruling: Court Demands Proof of Accessibility Fixes Before Paying Attorneys’ Fees
European Accessibility Act: Enforcement Underway
The European Accessibility Act became enforceable across EU member states on June 28, 2025. Through 2026 businesses have been adapting to its requirements across websites, e-commerce platforms, mobile apps, e-books, computers and operating systems, smartphones, ATMs, ticketing and check-in machines, television equipment, telephony services, audiovisual media services, passenger transport and banking services. Its breadth has made the EAA one of the most consequential accessibility regulations in force anywhere, and it reaches U.S. businesses serving European customers.
AI Is Changing Accessibility Workflows, Not Replacing Testing
AI-assisted accessibility tooling — real-time captioning, automated image description, document remediation and voice interfaces — continued to mature through 2026, and organisations are increasingly using it to accelerate remediation work. The consistent finding across the field is that these tools improve throughput without replacing human judgement: automated checks catch a minority of WCAG failures, and testing with users who rely on assistive technology remains the only reliable way to confirm that a site actually works.
CIPA: The Next Wave of Website Litigation
Readers of this report will recognise the pattern immediately: a small group of specialised California firms filing large numbers of near-identical claims against consumer-facing websites, backed by per-violation statutory damages. That is ADA website litigation. It is also, increasingly, privacy litigation under the California Invasion of Privacy Act (CIPA), where statutory damages reach $5,000 per violation and plaintiffs argue that figure can be counted per website visitor.
We tracked 206 CIPA website lawsuits filed in California between January 1 and June 30, 2026. For scale, California produced 424 ADA website lawsuits in the same period — so CIPA filings now run at roughly half the volume of accessibility filings in the same state. They are also far more concentrated in who files them and where. Every one of the 206 cases was filed in state court. Not one was filed in federal court.
Filing Volume and the June Spike
| Month | CIPA Lawsuits | Share of Half-Year | Quarter | Quarter Total |
|---|---|---|---|---|
| January | 32 | 15.5% | Q1 | 94 |
| February | 32 | 15.5% | Q1 | |
| March | 30 | 14.6% | Q1 | |
| April | 36 | 17.5% | Q2 | 112 |
| May | 24 | 11.7% | Q2 | |
| June | 52 | 25.2% | Q2 | |
| Total | 206 | 100.0% | 206 |
Filings held near 30 a month through the spring, dipped to 24 in May, then jumped to 52 in June — a single month accounting for a quarter of the entire half-year. The first quarter produced 94 cases and the second 112, a 19.1% increase. Almost all of that June spike came from one filer.
The two behave completely differently. Brodsky Smith filed at a steady pace all six months, never fewer than 13 and never more than 21. Pacific Trial Attorneys did the opposite: 8 cases in May, then 38 in June, producing nearly three-quarters of that month’s total on its own. They also pursue different targets — Pacific filed most often against financial and business services sites, Brodsky Smith against clothing and fashion.
Venue is just as concentrated. 187 of the 206 cases — 90.8% — were filed in Los Angeles County Superior Court, with San Diego (11), Orange County (4) and San Bernardino (4) accounting for the remainder. For a business defending one of these claims, that matters practically: the filing firms know the venue, its local rules and its judges. A defendant appearing there once does not.
Which Industries Are Targeted
| Industry | Lawsuits | Share | Cumulative |
|---|---|---|---|
| Clothing & Fashion | 44 | 21.4% | 21.4% |
| Furniture, Lighting & Home Decor | 39 | 18.9% | 40.3% |
| Financial & Business Services | 27 | 13.1% | 53.4% |
| Medical & Health | 23 | 11.2% | 64.6% |
| Restaurants & Food | 11 | 5.3% | 69.9% |
| 11 other industries | 62 | 30.1% | 100.0% |
| Total | 206 | 100.0% |
Online retail carries most of the exposure — clothing and fashion plus furniture and home decor together account for 40.3% of filings. But the rest of the top five sits outside retail entirely: financial and business services (27 cases) and medical and health (23), a group that includes insurance carriers, banks, credit unions and health plans, several of them large national companies. The top five industries account for 144 lawsuits, 69.9% of everything filed.
Why This Belongs in an Accessibility Report
CIPA claims target ordinary website tooling that most businesses run without a second thought: cookies, tracking pixels, analytics tags, session-replay software and chatbots — anything that can be characterised as intercepting or recording a visitor’s communications without proper consent.
The overlap with accessibility litigation is no longer theoretical. Manning Law, the second-most-active ADA firm in this report, is among the firms that have expanded into privacy claims, and combined complaints pairing website tracking allegations with accessibility allegations are now appearing against single businesses. For an online retailer, the website that attracts an ADA demand letter may attract a CIPA one as well — from a firm running both plays. One audit of what a website contains, what it collects and who can actually use it addresses both exposures.
Where the Law Stands: SB 690
Senate Bill 690 would curtail this category of lawsuit. It was introduced in February 2025 and passed the state Senate 35-0 in June 2025, then sat in the Assembly for more than a year. On July 1, 2026, the Assembly Committee on Privacy and Consumer Protection passed an amended version that narrows the “commercial business purpose” exemption to website and application activity, and removes the private right of action for pen register and trap-and-trace claims under Penal Code Section 638.51 — leaving only the California Attorney General able to bring them. Reports place the operative date at January 1, 2027.
What the bill does not fix: it leaves Section 631, the wiretapping provision, untouched. Plaintiffs argue the same website tools violate Section 631 as well, so if SB 690 passes in its current form the likely outcome is not that these lawsuits stop but that they are refiled under a different section of the same statute. The bill has been re-referred to Assembly Appropriations and must clear an Assembly floor vote and return to the Senate before August 31, 2026. Until then, CIPA exposure stays exactly where it is.
Also Moving: AB 2564
A second California bill belongs on the watch list. AB 2564, the Surveillance Pricing Protection Act, would make it unlawful for a retailer to set a “customized price” using personal information collected through electronic surveillance technology. It covers prices that move down as well as up, which pulls in cart-abandonment codes, win-back offers and personalized coupons; broad, publicly disclosed discounts are carved out.
It matters here for one reason: the enforcement structure is the same one that drives filing waves. Public prosecutors could sue for civil penalties and consumers could sue for injunctive relief plus attorney’s fees. Fee-shifting attached to a technical website requirement is precisely the structure behind both ADA and CIPA litigation. As of late July 2026 the bill has cleared its Senate committees and awaits a Senate floor vote before the session ends on August 31, 2026. Nothing is law yet.
Read our full breakdown of AB 2564 and what it means for online sellers.
A detailed analysis of California CIPA website litigation — including the full firm, venue and industry breakdowns, the mechanics of how these claims are constructed, and what businesses can do about them — will be published separately as an EcomBack special report.
What This Means for Businesses
Accessibility and privacy risk now arrive together. The same California courts, the same small group of firms, the same repeat plaintiffs, the same online retailers. A business preparing for one should prepare for both — and one website audit can cover both.
An accessibility widget is not compliance, and it is not privacy protection. 496 lawsuits in six months targeted sites that had one installed. Overlays adjust presentation at run time; they do not remediate code, and they do not touch tracking scripts at all.
Audit what your site loads before someone else does. Most privacy claims begin with an automated scan for third-party tracking. Know what your site runs — analytics, ad pixels, session replay, chat tools — and know whether you have real consent for it.
Do not wait for legislative relief. SB 690 would narrow CIPA claims but is not law, may not survive in its current form, and leaves the wiretapping provision open. AB 2564 could attach a third claim to the same website. Fixing consent and tracking is the only step that works regardless of what the legislature does.
Geography is no longer a defence. Illinois, Indiana and Minnesota together produced 688 filings this half-year. These laws follow the customer, not the seller: a California or Illinois resident visiting your store can pull you into their courts wherever your business sits.
Treat accessibility as a programme, not a project. The barriers cited most often in 2026 complaints — alternative text, form labels, keyboard operation, focus indicators, contrast — are the same ones cited in 2025. They recur because websites change continuously and one-time fixes decay.
Conclusion
The headline number for the first half of 2026 — 2,045 lawsuits, up 1.54% — suggests a plateau. The composition tells a different story. New York, the long-time centre of this litigation, shed 238 cases. Illinois nearly doubled. Indiana quadrupled. Shopify overtook custom-coded sites as the most-targeted platform. One law firm went from 248 filings to 526 and now accounts for a quarter of everything filed nationally.
Two patterns held firm through all of that churn. Litigation remains driven by a small number of repeat filers — 30 plaintiffs and 10 firms account for more than half and more than four-fifths of all cases respectively, both higher than a year ago. And shortcuts continue to fail: nearly a quarter of all lawsuits targeted websites that had already installed an accessibility widget.
Meanwhile the exposure is broadening beyond accessibility. CIPA privacy filings in California now run at roughly half the volume of the state’s accessibility filings, from just two firms, in largely one courthouse — and AB 2564 would open a third front on the same websites, using the same tracking data, with the same fee-shifting incentive.
The businesses that come through this well will be the ones that stop treating each of these as a separate compliance fire. One audit of what your website contains, what it collects, and who can actually use it addresses all three.
EcomBack's Accessibility Solutions
EcomBack is a digital accessibility company that helps businesses and public organizations improve website accessibility and achieve ADA and WCAG compliance through accessibility audits, remediation guidance, ongoing monitoring, and compliance support.
In addition to our accessibility services, EcomBack publishes one of the industry’s most comprehensive collections of ADA website accessibility lawsuit reports, providing detailed analysis of litigation trends across states, industries, platforms, plaintiffs, and law firms.
Our mission is to make digital accessibility more transparent and actionable by delivering reliable data, practical compliance solutions, and expert guidance that help organizations reduce legal risk while creating accessible digital experiences for everyone.
Remediation
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Accessibility Audits
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Ongoing Monitoring
Keep your website accessible as it evolves. Our continuous monitoring identifies new accessibility issues after updates and helps maintain long-term compliance.
Staff Training
Empower your team with practical accessibility training focused on WCAG requirements, inclusive design, and everyday best practices for building accessible digital experiences.
Accessibility Statements
Demonstrate your commitment to accessibility with professionally written accessibility statements that communicate your compliance efforts and support transparency.
Usability Testing
Real users with disabilities evaluate your website using assistive technologies, providing valuable insights that improve usability, accessibility, and the overall user experience.
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