Yes — courts have applied the Americans with Disabilities Act to mobile apps. The key case is Robles v. Domino’s Pizza, where a federal appeals court held in 2019 that the ADA covers Domino’s website and its app because both connect customers to the goods and services of its physical restaurants — and the Supreme Court let that ruling stand. If your business has an ordering, booking, or loyalty app, the practical answer is that it needs to be accessible, just like your website.
The law itself never says the word “app.” Here’s how we got from a 1990 statute about buildings to a legal standard that reaches the phone in your customer’s pocket — and what a small business with an app should actually do about it.
The ADA never mentions apps — so why does it apply?
Title III of the ADA requires “places of public accommodation” — restaurants, shops, hotels, medical offices, and most other businesses open to the public — to offer people with disabilities full and equal enjoyment of their goods and services. The statute was written in 1990, so it lists physical places, not websites or software. Courts have spent two decades deciding how far it stretches into digital, a story we cover on the web side in our guide to ADA Title III and websites.
Mobile apps entered that story through a pizza order. When Domino’s argued its app was outside the law, the Ninth Circuit disagreed — and because the Supreme Court declined to review the decision, it remains the leading precedent. In the opinion itself, the court held that the ADA applies to Domino’s website and app because they “connect customers to the goods and services of Domino’s physical restaurants” — which is exactly what most small-business apps do: they are a second front door to the same store.
What happened in Robles v. Domino’s?
Guillermo Robles, a blind screen-reader user, tried to order a customized pizza through Domino’s website and iPhone app and couldn’t complete the order. He sued in 2016. Domino’s made two arguments that many businesses still reach for today: that the ADA doesn’t cover its digital properties, and that it couldn’t fairly be held liable when the government had never issued specific technical rules for websites or apps.
Both arguments lost. Here’s the case at a glance:
| Date | What happened |
|---|---|
| 2016 | Robles sues Domino’s over its inaccessible website and mobile app |
| January 2019 | Ninth Circuit rules the ADA applies to both, Robles v. Domino’s Pizza, 913 F.3d 898 (9th Cir. 2019) |
| October 7, 2019 | Supreme Court denies Domino’s petition, leaving the ruling in place |
| June 2021 | Trial court grants summary judgment for Robles on the website, orders WCAG 2.0 conformance, and awards $4,000 under California’s Unruh Act |
| June 6, 2022 | The parties settle, ending six years of litigation |
The Ninth Circuit also rejected the fair-notice defense. Per the Southeast ADA Center, the court held the ADA’s requirement of “full and equal enjoyment” gave Domino’s all the notice it needed, even without a technical regulation. In 2021 the trial court ordered the website brought into WCAG conformance and awarded statutory damages under California’s Unruh Act before the case settled in June 2022, according to the Bureau of Internet Accessibility’s account of the settlement.
Six years of appellate litigation, likely millions in legal fees — over app buttons a screen reader couldn’t announce. Unlabeled controls remain one of the most common failures we see, and they map directly to WCAG 4.1.2, Name, Role, Value.
Does it matter where my business is located?
Less than you’d hope. Federal appeals courts do disagree about the theory: according to Purdue Global Law School’s analysis, the Third, Sixth, Ninth, and Eleventh Circuits require a digital service to have a “nexus” to a physical place of public accommodation, while courts in the First, Second, and Seventh Circuits have held a website can be a public accommodation with no physical connection at all. The Supreme Court left that split unresolved when it turned down the Domino’s petition.
For a small business with an ordering or booking app, neither camp is a safe harbor. If you have a physical location, your app has the nexus the stricter circuits require — that was Domino’s exact situation. If you’re online-only, plaintiffs file where the broader theory applies: Seyfarth Shaw’s 2025 count puts New York first at 1,021 federal web accessibility suits and Florida second at 961. Our state pages break down what filing patterns look like in New York and Florida.
How real is the lawsuit risk in 2026?
The overall numbers are climbing again. According to Seyfarth Shaw, plaintiffs filed 3,117 website accessibility lawsuits in federal court in 2025 — a 27% jump from 2,452 in 2024 — and those suits made up 36% of all ADA Title III federal filings. Counting state courts, UsableNet tracked more than 5,000 digital accessibility lawsuits in 2025 across websites, apps, and video content, with e-commerce businesses the target nearly 70% of the time.
Apps have been part of that wave since the Domino’s ruling. Defense firm Rumberger Kirk predicted after the Supreme Court’s 2019 denial that suits “focused on the inaccessibility of mobile apps will continue to proliferate,” noting businesses were already seeing more pre-suit demand letters aimed at apps. That matters for how you think about exposure: the same plaintiff’s firm that tests your website with a screen reader can run the identical test on your app, and a demand letter frequently covers both.
What about government apps? The Title II rule
For state and local governments, the question is no longer judge-made law — it’s regulation. The Department of Justice’s 2024 rule under Title II explicitly requires government web content and mobile apps to conform to WCAG 2.1 Level AA. According to ADA.gov’s fact sheet, the compliance deadlines — extended by one year in an interim final rule published April 20, 2026 — are now April 26, 2027 for governments serving 50,000 or more people and April 26, 2028 for smaller ones and special districts.
Why should a private business care? Because the DOJ chose a specific technical standard for apps, and courts and settlement agreements tend to follow it. We unpack the rule in our Title II web rule explainer. If you run a restaurant, clinic, or shop with an app, the writing on the wall says: measure it against the same yardstick.
What standard does my app actually have to meet?
There is no separate “app law” — the working standard is WCAG 2.1 Level AA, applied to native iOS and Android interfaces. WCAG 2.1 specifically added mobile-relevant criteria on top of 2.0, and it’s the version the DOJ codified for government apps. In practice, the barriers that generate app complaints are the same ones that generate web complaints:
- Buttons and icons with no accessible name, so VoiceOver or TalkBack announces “button” and nothing else — a Name, Role, Value failure
- Images and product photos with no text alternative (WCAG 1.1.1)
- Text and controls that fail minimum color contrast
- Checkout and booking forms whose fields and error messages aren’t announced (WCAG 3.3.2)
A 15-minute self-check for your ordering or booking app
You don’t need to be technical to find the worst problems. Every iPhone and Android phone ships with the same screen reader your customers — and plaintiffs’ testers — use.
- Turn on the screen reader. iPhone: Settings, then Accessibility, then VoiceOver. Android: Settings, then Accessibility, then TalkBack.
- Open your app and swipe right to move through elements one at a time. Listen: does every button announce what it does, or do you hear “button” with no name?
- Attempt the money task. Add an item to the cart, pick an appointment slot, or start an order — using only swipes and double-taps, without looking if you can manage it.
- Trigger an error. Submit a form with a field missing. Does the screen reader tell you what went wrong and where?
- Write down every dead end — the screen, the control, what was announced. That list is exactly what a manual accessibility audit would formalize, and what your developer needs to start fixing.
If you got stuck on step 3, so will a blind customer — and that unfinished order is precisely the fact pattern Robles was built on. Restaurants with online ordering should read our restaurant accessibility page for how these failures cluster in that industry.
Where to start
The ADA reaches your app the same way it reaches your website: both are doors to your business, and both have to open for everyone. The good news is that the fixes are known, testable, and far cheaper than six years of litigation.
Start with the door plaintiffs test first. Your website shares content, checkout flows, and often code with your app — and website suits outnumber everything else. Run a free accessibility scan to see where your web presence stands, and you’ll have a concrete picture of the risk your whole digital storefront carries.