Reference · United States
ADA website case law, by circuit
Whether Title III of the Americans with Disabilities Act reaches a website depends on which federal circuit you are in, and on distinguishing the decisions that bind from the ones that were vacated, denied review, or never reached the question. This page keeps that list current. Every entry links to the opinion or to our case study of it.
Updated September 2026Reviewed by The Accessibility.build team
Key facts
- Circuits requiring a nexus to a physical place before a site is covered
- 5Third, Sixth and Ninth Circuit decisions,
- Circuits where a website can be a public accommodation on its own
- 2Carparts (1st Cir.) and Doe v. Mutual of Omaha (7th Cir.),
- Appellate decisions in force holding websites are outside Title III
- 0The Eleventh Circuit vacated its own in December 2021,
- Circuits with no controlling website decision either way
- 64th, 5th, 8th, 10th, D.C. and Federal Circuits,
- Damages available to a private plaintiff under Title III
- $042 U.S.C. 12188; every dollar in these cases came from state law,
- Web accessibility case ever tried to judgment
- 1Gil v. Winn-Dixie, June 2017,
Where each circuit stands today
Where each federal circuit stands
Robles binds the Ninth Circuit. It does not settle the country, and the answer to “does this apply to us” still depends on where a claim is brought.
A physical nexus is required
3rd6th9thThe site is covered when it connects customers to a physical place of business. This is the rule Robles settled for the Ninth.
A website can qualify on its own
1st7thNo physical connection is needed; a site offering the goods and services Title III lists is covered by itself.
District courts are divided
2ndNo controlling appellate holding, and trial courts within the circuit have gone both ways.
Unsettled after a vacated opinion
11thA panel held a website was not a public accommodation, then the court vacated that opinion as moot in December 2021. Nothing binding survives it.
Not squarely decided at appellate level
4th5th8th10thD.C.Fed.No controlling decision on whether Title III reaches a website.
Positions as at 2026. Circuit numbers are shown as chips; a business is exposed to the rule of the circuit where it is sued, not where it is based.
The decisions, in order
Status matters more than the headline. A vacated opinion has no precedential effect, a denial of certiorari decides nothing, and a district court binds no other court. Only five of these thirteen entries are binding appellate authority, and none of the five was about a website when it was decided.
| Date | Court | Case | What it held | Status |
|---|---|---|---|---|
| 1st Cir. | Carparts Distribution Center v. Automotive Wholesaler's Association37 F.3d 12 | Public accommodations are not limited to physical structures. Decided about an insurance plan, before commercial websites existed; applied to websites by district courts in the circuit, including the Netflix captioning case in 2012. | Binding in circuit | |
| 6th Cir. | Parker v. Metropolitan Life Insurance121 F.3d 1006 | Title III covers physical places; a nexus between the challenged service and a physical place is required. | Binding in circuit | |
| 3rd Cir. | Ford v. Schering-Plough145 F.3d 601 | A public accommodation is a physical place; a benefit without a nexus to a physical place is outside Title III. The origin of the nexus reading later applied to websites. | Binding in circuit | |
| 7th Cir. | Doe v. Mutual of Omaha Insurance179 F.3d 557 | In dicta, a place of public accommodation includes facilities open to the public in both physical and electronic space, including websites. The holding itself concerned insurance terms. | Binding in circuit | |
| 9th Cir. | Weyer v. Twentieth Century Fox Film198 F.3d 1104 | Places of public accommodation are actual, physical places; services must have a nexus to one. The rule the Target and Domino's courts applied. | Binding in circuit | |
| 11th Cir. | Rendon v. Valleycrest Productions294 F.3d 1279 | Title III reaches intangible barriers, here a telephone screening line, that block access to the privileges of a physical place. Both sides of the Winn-Dixie appeal relied on it. | Binding in circuit | |
| N.D. Cal. | National Federation of the Blind v. Target452 F. Supp. 2d 946 | The ADA reaches a retailer's website to the extent its inaccessibility impedes enjoyment of the goods and services of the stores, and not otherwise. The first ruling against a retailer and the origin of the website nexus test. | District court only | |
| S.D. Fla. | Gil v. Winn-Dixie Stores (trial)257 F. Supp. 3d 1340 | After the only trial in the field, the website was a service of the stores and its inaccessibility violated Title III; injunction to WCAG 2.0 with no level named. | Vacated, binds nobody | |
| 9th Cir. | Robles v. Domino's Pizza913 F.3d 898 | Title III applies to a website and app that connect customers to a physical restaurant's goods and services; the absence of a federal technical standard does not deny fair notice. Expressly did not decide the no-nexus case. | Binding in circuit | |
| U.S. Supreme Court | Domino's Pizza v. RoblesNo. 18-1539, cert. denied | Review declined without comment. A denial of certiorari decides nothing and creates no precedent. | Denial of review, no holding | |
| 11th Cir. | Gil v. Winn-Dixie Stores (panel)993 F.3d 1266 | Two to one: websites are not places of public accommodation, and a site that sells nothing is not an intangible barrier to the stores. Vacated eight months later because the injunction had expired. | Vacated, binds nobody | |
| C.D. Cal. | Robles v. Domino's Pizza (summary judgment)No. 2:16-cv-06599 | Domino's website violated Title III; ordered to conform to WCAG 2.0, no level and no deadline; $4,000 under California's Unruh Act. App claims never decided; settled June 2022. | District court only | |
| 11th Cir. | Gil v. Winn-Dixie Stores (rehearing)21 F.4th 775 | The appeal was moot; the panel opinion and the trial judgment are vacated and the case dismissed. The Eleventh Circuit has no controlling decision on websites. | Vacated, binds nobody |
How to read this
The nexus test is a limit, not a grant. It was written in 2006 by a court ruling for the plaintiffs, and it dismissed the claim for everything on Target.com unconnected to the stores. In the Third, Sixth and Ninth Circuits a website is covered when it connects customers to a physical place, and the question of a purely online business is expressly open.
The First and Seventh Circuit rules predate the web. Carparts and Mutual of Omaha were about insurance. District courts in those circuits have applied them to websites, most prominently to Netflix in 2012, but neither appeals court has decided a website case.
Winn-Dixie is the entry most often cited wrongly. The April 2021 panel opinion is still quoted, in briefs and in sales material, as the Eleventh Circuit's position. The court withdrew it in December 2021 because the injunction under appeal had expired. Florida, Georgia and Alabama have no appellate rule.
Money comes from state law. Title III allows an injunction and fees, nothing more. The $4,000 in Domino's and the $6 million fund in Target were both California statutory damages, which is why California and New York dominate the filing statistics.
The regulator's position is on the record. The Justice Department told the Winn-Dixie trial court in December 2016 that a grocery chain's website must be accessible unless doing so is an undue burden, and its 2024 rule requires WCAG 2.1 AA of state and local government under Title II. There is still no technical regulation for private business under Title III.
Analysis, not legal advice. Last reviewed 3 September 2026; the table is updated when a circuit rules. The three case studies carry the full sourcing for their entries.
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