Robles v. Domino's Pizza — Ninth Circuit Holds the ADA Applies to a Company's Website and App

In September 2016 Guillermo Robles, who is blind, sued Domino's Pizza, LLC, alleging its website and mobile app could not be used with screen-reading software and so breached Title III of the Americans with Disabilities Act. Barriers cited included missing alt text, empty links and redundant links.
Domino's argued that the ADA does not reach websites absent specific DOJ technical standards and that applying it would violate its Fourteenth Amendment due-process rights. The district court dismissed the case, invoking the primary-jurisdiction doctrine to await DOJ rulemaking.
On 15 January 2019 the Ninth Circuit (Judges Watford and Owens) reversed and remanded. It held that Title III applies to Domino's website and app because they connect customers to the goods and services of its physical restaurants, that Domino's had received fair notice that its digital content must be accessible even without DOJ regulations, and that the primary-jurisdiction doctrine did not justify dismissal. The Supreme Court declined to review the decision in October 2019.
On remand, a 2021 summary-judgment ruling awarded Robles $4,000 in statutory damages under California's Unruh Act, and the case settled on 6 June 2022 on undisclosed terms.
Caution: this is a legal precedent, not a measured accessibility programme. It established that businesses in the Ninth Circuit cannot rely on the absence of DOJ web rules, but the settlement terms are not public, so the concrete remediation and its effect on users are not documented. The ruling is circuit-level and its scope for websites without a physical-location nexus was left open.

Read the full analysis: https://cdn.ca9.uscourts.gov/datastore/opinions/2019/01/15/17-55504.pdf