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Compliance Guide • New York State & City Law
New York is the epicenter of federal website accessibility litigation. Plaintiff- friendly case law in the Southern and Eastern Districts, damages under the State and City Human Rights Laws, and an industrialized serial-plaintiff bar make it the venue every consumer-facing website has to plan around.
2025 Federal Filings (NY)
1,021
#1 state in the nation
Key Venues
SDNY / EDNY
Manhattan & Brooklyn federal courts
Top Target Industry
E-Commerce
~70% of filings nationally
State/City Law Damages
Yes
NYSHRL & NYCHRL add exposure
In 2025, New York federal courts recorded 1,021 website accessibility lawsuits — more than any other state and roughly a third of the national federal total of 3,117. The vast majority land in the Southern District of New York (Manhattan) and the Eastern District of New York (Brooklyn). Three structural factors drive the concentration:
For where New York fits in the broader federal picture — including the circuit split and the DOJ's Title II web rule — see our ADA website compliance guide. Year-by-year and state-by-state data lives in the accessibility lawsuit tracker.
New York layers two anti-discrimination statutes on top of the ADA, and both have been applied to websites:
Separately, New York State policy requires state agency websites to meet WCAG-based accessibility standards — so public-sector sites in New York face both the DOJ Title II web rule and state policy. How New York's requirements compare with other jurisdictions is mapped in our accessibility laws tracker.
New York's filing volume is not thousands of unrelated grievances — it is a repeatable litigation model. Individual plaintiffs frequently appear in dozens or even hundreds of cases, represented by the same firms, using complaints that differ mainly in the defendant's name and the screenshot exhibits. Nationally, nearly half of recent federal defendants had been sued before, and a growing share of filings are drafted with the help of automated scanners and generative AI, which has pushed filing costs toward zero.
The standard playbook: run an automated scan of a consumer site, confirm a handful of WCAG failures with a screen reader, file in SDNY or EDNY pleading ADA, NYSHRL, and NYCHRL counts, and settle for a payment plus a remediation agreement. Because settlements with one plaintiff do not bind the next, businesses that settle without actually fixing their sites are frequently sued again — repeat-defendant suits are among the fastest-growing categories.
Courts have shown intermittent skepticism — dismissals for lack of standing where a plaintiff cannot plausibly allege an intent to return to the site, and scrutiny of boilerplate pleading — but no development to date has meaningfully slowed the volume. Settlement economics and defense costs are detailed in our lawsuit cost guide.
E-commerce and retail account for roughly 70% of website accessibility filings, and New York's docket skews even harder toward online selling because its case law reaches online-only businesses. Recurring defendant profiles:
The common thread is not industry but architecture: template-driven consumer sites where one inaccessible component — an unlabeled icon button, a keyboard-trapped carousel — repeats across thousands of pages and shows up instantly in a scan. Gauge your own site's red flags with the ADA compliance risk checker.
Three reinforcing reasons. First, favorable case law: many decisions from the Southern and Eastern Districts of New York treat websites as covered by ADA Title III even without a tie to a physical store, so online-only businesses can be sued there. Second, damages: the New York State and New York City Human Rights Laws add compensatory damages (and under the City law, punitive damages and civil penalties) to an ADA claim that alone would yield only an injunction and fees. Third, infrastructure: an established group of plaintiffs' firms and repeat plaintiffs files hundreds of near-identical complaints per year. In 2025, New York led all states with 1,021 federal website accessibility filings.
Yes. The New York State Human Rights Law (NYSHRL) and the New York City Human Rights Law (NYCHRL) both prohibit disability discrimination in places of public accommodation, and courts have applied them to websites. The NYCHRL is by statute construed liberally — more broadly than its federal counterpart — and covers businesses serving New York City residents. These claims are routinely pleaded alongside ADA counts, converting a fees-and-injunction case into one with damages exposure.
Yes. Unlike the Ninth Circuit's nexus requirement and California state case law, many SDNY and EDNY decisions have held that a website can itself be a place of public accommodation under ADA Title III — Andrews v. Blick Art Materials (EDNY 2017) is a frequently cited example. That is precisely why plaintiffs targeting e-commerce companies with no physical stores overwhelmingly choose New York federal courts. An out-of-state company that ships to New York customers should assume it can be named there.
The complaints are highly standardized. A plaintiff who is blind and uses a screen reader (JAWS, NVDA, or VoiceOver) alleges they attempted to browse or purchase from the defendant's website and encountered WCAG failures: images without alt text, unlabeled buttons and form fields, inaccessible dropdown menus, missing skip links, keyboard traps in carousels or checkout. The complaint seeks an injunction requiring WCAG conformance, damages under the State and City Human Rights Laws, and attorney's fees. Many firms file dozens of these against different defendants in a single month.
E-commerce and retail dominate, consistent with the national pattern where they account for roughly 70% of filings — apparel, beauty, food and beverage brands, and consumer packaged goods are especially common targets because their sites are transactional and their customer bases are national. Restaurants and food services, entertainment and media, healthcare, and financial services follow. Companies with high-revenue consumer sites and frequent template changes (which reintroduce accessibility regressions) face the greatest repeat exposure — nearly half of recent federal defendants had been sued before.
The ADA itself allows only injunctive relief and attorney's fees in private suits. The NYSHRL adds compensatory damages for proven harm, and the NYCHRL goes further, allowing compensatory damages, punitive damages, and civil penalties, with a liberal construction mandate. In practice, most cases settle before damages are tested — typical settlements combine a monetary payment (commonly in the five figures once fees are included) with a remediation agreement specifying WCAG 2.1 AA conformance on a timeline.
Remediate to WCAG 2.1/2.2 Level AA with priority on the flows plaintiffs actually test: home page, product listing and detail pages, cart, checkout, and account creation, verified with screen readers and keyboard-only navigation. Publish an accessibility statement with a monitored contact channel, fix reported issues quickly, and retest after site redesigns — regressions after a settlement invite follow-on suits from new plaintiffs, which no prior settlement bars. An independent audit provides both the fix list and documentation of good-faith effort.
This page is provided for general educational purposes only and does not constitute legal advice. New York case law on website accessibility — including standing doctrine and the scope of the State and City Human Rights Laws — continues to develop. For advice about your specific situation, consult an attorney experienced in digital accessibility litigation.
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