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Seyfarth Synopsis: ADA Title III lawsuit filings in federal courts remained steady in 2025, with California, Florida, and New York retaining the top three spots for filings, and no slowdown in sight.
We've been tracking ADA Title III cases in federal court for 13 years now, starting back when there were fewer than 3,000 cases filed in an entire year. The number of cases climbed to a high of 11,452 in 2021 and then dropped to the 8,000 range where it remained in 2025.
There were 8,667 ADA Title III lawsuits filed in or removed to federal district courts in 2025 – 2% fewer than in 2024. Despite the slight decline, the number is still three times higher than the number of filings in 2013, when we first started compiling this data.
[Total Number of ADA Title III Federal Lawsuits Filed Each Year, January 1, 2013 – December 31, 2025; 2013: 2,722; 2014: 4,436 – 63% increase over 2013; 2015: 4,789 – 8% increase over 2014; 2016: 6,601 – 38% increase over 2015; 2017: 7,663 – 16% increase over 2016; 2018: 10,163 – 33% increase over 2017; 2019: 11,053 – 9% increase over 2018; 2020: 10,982 – 1% decrease from 2019; 2021: 11,452 – 4% increase over 2020; 2022: 8,694 – 24% decrease from 2021; 2023: 8,227 – 5% decrease from 2022; 2024: 8,800 – 7% increase over 2023; 2025: 8,667 – 2% decrease from 2024]
California retained its top spot with 3,252 lawsuits. Florida moved into second place with 1,823 cases. For the second year in a row, New York federal courts took the third spot with 1,471 cases. New York's change in position reflects the migration of plaintiffs to New York and New Jersey state court after the federal courts started applying more rigorous standing requirements in website accessibility cases.
[California, New York, Florida ADA Tile III Federal Lawsuits 2013-2025: California: 2013: 995; 2014 1,866; 2015: 1,659; 2016: 2,458; 2017: 2,751; 2018: 4,249; 2019: 4,794; 2020: 5,869; 2021: 5,930; 2022: 2,519; 2023: 2,380; 2024: 3,252; 2025: 3,252; Florida: 2013: 816; 2014: 1,553; 2015: 1,338; 2016:1,663; 2017: 1,488; 2018: 1,941; 2019: 1,885; 2020: 1,208; 2021: 1,054; 2022: 1,350; 2023: 1,415; 2024: 1,627; 2025: 1,823; New York: 2013: 125; 2014: 212; 2015: 366; 2016: 543; 2017: 1,023; 2018: 2,338; 2019: 2,635; 2020: 2,238; 2021: 2,774; 2022: 3,173; 2023: 2,759; 2024: 2,220; 2025: 1,471]
Illinois is #4 on the list with 659 federal lawsuits – 260 more than in 2024. It appears that some of the most prolific New York plaintiffs' lawyers have moved their work to this state. Missouri is #5 on the list with 183 cases, moving up from 7th position in 2024 when it had 135 cases.
Rounding out the Top Ten are Minnesota (179), Texas (177), Pennsylvania (95), New Jersey (91) and Indiana (88). The Hoosier state is a newcomer to the list, pushing out Georgia.
[Top 10 States with Federal ADA Title III Lawsuits Filed January 1, 2025 – December 31, 2025: California: 3,252; Florida: 1,823; New York: 1,471; Illinois: 659; Missouri: 183; Minnesota: 179; Texas: 177; Pennsylvania: 95; New Jersey: 91; Indiana: 88]
The only states with no federal ADA Title III lawsuits in 2025 were Montana, North Dakota and South Dakota.
We have no reason to believe that the numbers will change much in 2026, though more cases might shift to state court. In the past few years, California courts have been aggressively declining supplemental jurisdiction over state law claims in cases alleging ADA Title III violations, thereby eliminating monetary damages for the plaintiff. As a result, many plaintiffs have opted to file in state court. And as discussed above, New York federal courts are less receptive to plaintiffs in website accessibility cases than they once were. Stay tuned for our annual crystal ball blog post for 2026 predictions for ADA Title III litigation and DOJ enforcement.
A note on our methodology: Our research involves a painstaking manual process of going through all federal cases that were coded as "ADA-Other," manually culling out the ADA Title II cases in which the defendants are state and local governments, and categorizing them by state. The manual process means there is the small possibility of human error.
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