[co-author: Susan Ryan]
Seyfarth Synopsis: Mid-year federal lawsuit counts show a continued rebound trend from 2023’s low.
Since we started tracking ADA Title III lawsuits filed in federal courts at the mid-point of the year in 2017, we’ve seen ebbs and flows of activity in the first six months of each year. In 2021 we saw the high water mark, with 6,304 cases filed. Only two years later, in 2023, cases were at their lowest, with only 4,081 filings. Last year, the numbers rebounded a little, and this year, that tide continues to rise.
In 2024, 4,280 ADA Title III cases were filed in federal courts between January and June. In 2025, that number climbed to 4,575. That’s a 7% increase year-over-year. Nothing like the 33% increase between 2020 and 2021, but not a downturn either. If the filing numbers remain steady for the rest of the year, 2025 will see approximately 9,100 cases which would represent a 3.4% increase over 2024 when there were 8,800 federal ADA Title III case filings.
[Mid-Year ADA Title III Federal Lawsuit Filings 2017-2025; 2017: 4,127; 2018: 4,965, 20% Increase from 2017; 2019: 5,592, 12% Increase from 2018; 2020: 4,751, 15% Decrease from 2019; 2021: 6,304, 33% Increase from 2020; 2022: 4,914, 22% Decrease from 2021; 2023: 4,081, 17% Decrease from 2022; 2024: 4,280, 5% Increase from 2023; 2025: 4,575, 7% Increase from 2024]
Here are the top ten states with the highest number of cases filed so far this year:
[2025 Mid-Year Federal ADA Title III Filings for Top 10 States: CO/GA/MN: 34; IN: 48; NJ: 62; MN: 94; MO: 101; TX: 116; IL: 270; NY: 837; FL: 989; CA: 1,735]
California had by far the highest number of filings, with 1,735. Florida follows with 989, and New York, with 837. Although Florida overtook New York in the second position, the real surprise is in fourth place: Illinois moved up from sixth last year. Texas is in fifth place, with 116 cases filed. Rounding out the top 10 are: Missouri (101), Minnesota (94), New Jersey (62), Indiana (48) and a 3-way tie for 10th: Colorado, Georgia and Wisconsin – all with 34 filings each.
Illinois is the big surprise this year – and likely took some of New York’s market share, as we’ve seen some New York law firms that used to file significant numbers of cases in New York now filing in Illinois. This may be due to judges in New York becoming increasingly frustrated with webite accessibility lawsuits, and looking at the cases more critically. The increasing number is also a bit surprising given that we’ve seen and predicted that plaintiffs’ attorneys will focus more on filing in state courts. We do not track state court filing numbers due to lack of a reliable system to pull that data, but anecdotally have seen that trend.
Check back with us in early 2026 when we’ll have final numbers for the entire year.
Our Methodology: Our overall ADA Title III lawsuit numbers come from the federal court’s docketing system, PACER. However, because the area of law code that covers ADA Title III cases also includes ADA Title II cases, our research department reviews the complaints to remove those from the count.
