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Pennsylvania website accessibility lawsuits: what the 2025 numbers actually show.
Pennsylvania businesses are covered by the federal Americans with Disabilities Act and by the Pennsylvania Human Relations Act, enforced through the Pennsylvania Human Relations Commission, which prohibits disability discrimination in places of public accommodation. Pennsylvania businesses faced 137 federal website accessibility lawsuits in 2025, up from 103 the year before, real and growing, though at a fraction of the pace seen in New York, Florida, or Illinois. Pennsylvania's federal courts have also produced at least one notable case dismissing a similar claim outright, a genuinely rare outcome. Here is what that means if you run a site based in, or selling to, Pennsylvania.
Last updated October 2026. Filing data reflects full year 2025 federal court records.
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The Pennsylvania Human Relations Act, and a real case worth knowing about
The Pennsylvania Human Relations Act (PHRA) prohibits discrimination on the basis of disability across several areas, including public accommodations, and is enforced through the Pennsylvania Human Relations Commission. As with most states without a specific website accessibility statute, PHRA claims are typically pleaded alongside a federal ADA Title III claim rather than as a standalone theory.
Most website accessibility lawsuits nationally depend on a “physical nexus” argument, the idea that a website counts as a place of public accommodation because of its close connection to a physical business. In January 2024, a federal judge in the Western District of Pennsylvania actually rejected that argument in a specific case, Murphy v. Spongelle LLC, dismissing the lawsuit and finding that the website in question did not have the kind of physical nexus Title III requires. That kind of outright dismissal on the merits is genuinely uncommon nationally, most courts that have addressed the question have let similar claims proceed.
One case is not a guarantee. Pennsylvania still saw 137 federal website accessibility lawsuits in 2025, so courts in the state clearly are not dismissing these claims wholesale. What the Spongelle decision does show is that Pennsylvania's federal courts, part of the Third Circuit, have demonstrated a real, documented willingness to scrutinize the underlying legal theory rather than accept it automatically, which is a genuinely different posture than states where that argument almost never succeeds.
Pennsylvania lawsuit filings and settlement data (2025)
| Year | Pennsylvania federal website accessibility lawsuits | Change from prior year |
|---|---|---|
| 2024 | 103 | |
| 2025 | 137 | up about 33 percent |
Pennsylvania's growth is real but modest next to Illinois's, whose far faster increase pushed Pennsylvania from fourth place nationally in 2024 down to fifth in 2025, even though Pennsylvania's own filing count went up, not down. That distinction matters: Pennsylvania is not losing ground because its litigation risk is falling, it is being outpaced by a faster-growing state elsewhere.
Typical demand-letter and settlement ranges
Typical demand-letter and settlement ranges, per defense-side reporting rather than any official court record: commonly $10,000 to $40,000, with cases that are ignored or escalate to active litigation tending toward the higher end or beyond, on top of separate legal fees either way. Axeazy does not predict the outcome of any individual case.
Source: Seyfarth Shaw's 2024 and 2025 ADA Title III website accessibility tracking reports.
Which businesses in Pennsylvania are actually being targeted
Industry
Retail and restaurant businesses see the most claims in Pennsylvania.
Venue
Filings occur across Pennsylvania's federal districts, including the Eastern District (Philadelphia) and the Western District (Pittsburgh and Erie), the latter being where the Spongelle dismissal originated.
Filing pattern
A small number of law firms and repeat plaintiffs are responsible for a large share of Pennsylvania's filings, a pattern confirmed across multiple years of independent litigation tracking. We are not naming specific firms or plaintiffs. That detail changes constantly, and Axeazy cannot independently verify it case by case.
If you have received a demand letter and are not sure what happens next, see the step by step walkthrough on what an ADA demand letter actually asks for and how to respond.
Axeazy fixes 14 categories of WCAG violations at the code level, not with an overlay widget, including the alt text, form label, and color contrast issues most often cited in demand letters. See what Axeazy fixes and what it does not.
Pennsylvania website accessibility: FAQ.
Do small businesses in Pennsylvania have to meet website accessibility requirements?
Yes. Both federal ADA Title III and the Pennsylvania Human Relations Act can apply to a business website, and courts in the state have allowed most such claims to proceed. Size alone has not been treated as an exemption.
Did a Pennsylvania court really rule that websites are not covered by the ADA?
Not exactly. In one specific case, Murphy v. Spongelle LLC, decided in January 2024, a federal judge in the Western District of Pennsylvania dismissed a particular claim after finding it did not meet the required connection between the website and a physical business. Pennsylvania still saw 137 similar lawsuits move forward in 2025.
What does a Pennsylvania accessibility demand letter usually ask for?
Pennsylvania letters usually cite Title III, often with the Pennsylvania Human Relations Act. Since a federal judge in the Western District dismissed a similar claim in Murphy v. Spongelle for lack of a physical nexus, whether your website connects to a physical location is worth raising with your attorney.
How much does a Pennsylvania accessibility lawsuit typically cost to resolve?
Reported Pennsylvania ranges commonly run $10,000 to $40,000, before separate legal fees. A strong physical nexus defense of the kind that succeeded in Murphy v. Spongelle can change that math, though one dismissal does not guarantee another. These are reported ranges, not a quote.
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Scope of this analysis
SCOPE LIMITATION: This report documents violations identified by automated WCAG 2.2 AA scanning using axe-core v4.11.0. Automated tools identify approximately 30 to 40% of all WCAG criteria. This report does not constitute legal advice, guarantee ADA compliance, or protect against legal action. ADA compliance is a legal determination made by courts. For full WCAG conformance assessment, engage an IAAP-certified accessibility professional.
Sources: Seyfarth Shaw, “Federal Court Website Accessibility Lawsuit Filings Bounce Back in 2025” (March 2026); Seyfarth Shaw, “Federal Court Website Accessibility Lawsuit Filings Continue to Decrease in 2024” (April 2025); Pennsylvania Human Relations Act, Pennsylvania Human Relations Commission; Murphy v. Spongelle LLC, W.D. Pa., decided January 24, 2024. Pennsylvania count reflects full year 2025 federal filings.
New Jersey sits in the same Third Circuit as Pennsylvania, and Ohio's federal courts apply similar nexus reasoning to website claims. See New Jersey lawsuit data, Ohio website accessibility law, or see all 10 states.