ADA lawsuits in California run at a volume no other state comes close to because of one state law: the Unruh Civil Rights Act, which turns every federal ADA violation into a claim worth at least $4,000 in statutory damages per occasion.1California Civil Rights Department. Unruh Civil Rights Act Federal ADA law alone gets a plaintiff a court order and attorney’s fees, but no money. Unruh adds the money, and that changes everything about how these cases are filed, priced, and settled.
In 2025, federal ADA Title III filings hit 8,667 nationally, and California accounted for nearly 40 percent of them — more than any other state by a wide margin.2San Diego Union-Tribune. Its Time to Reform Abusive ADA Lawsuits in California State-court filings under Unruh add to that total but are harder to track.
Why the Unruh Act Drives the Volume
The Unruh Act requires businesses to comply with the ADA and provides a minimum of $4,000 in statutory damages for each occasion a person is denied access, on top of actual damages, attorney’s fees, and costs.1California Civil Rights Department. Unruh Civil Rights Act Each visit to a noncompliant business, or even each instance of being deterred from visiting, can count as a separate occasion. A single plaintiff visiting several locations, or the same location on different days, can stack claims fast.
The federal ADA on its own has none of that. Its remedies are injunctive: fix the violation, pay the plaintiff’s lawyer. The dollar incentive is entirely a creature of state law, which is why California’s docket looks nothing like the rest of the country’s.
What a Typical Lawsuit Looks Like
Critics call much of the filing activity “drive-by” litigation. Plaintiffs or their consultants identify potential violations from a car, from satellite imagery, or by testing a website with screen-reading software, and file suit without notifying the business first.3ALEC. Drive-By Lawsuits and the Abuse of the Americans With Disabilities Act The alleged violations are frequently technical: a parking-lot slope a fraction of a degree too steep, a sign mounted slightly too high, a restroom mirror at the wrong height, a checkout page that doesn’t work with a screen reader. Each deficiency can be treated as its own violation.
Once served, most businesses settle rather than fight. Litigating an ADA case to verdict runs roughly $50,000 to $150,000, and even a quick settlement typically costs $10,000 to $50,000.4Law PLA. What to Do When Served With an ADA Compliance Lawsuit in California Individual claims often resolve in the $10,000 to $25,000 range, according to Los Angeles Times reporting.5Los Angeles Times. Los Angeles Restaurants Disability Lawsuits
Who Is Filing These Suits
A small group of plaintiffs and firms drives most of the docket. Nationally in 2025, just 33 plaintiffs accounted for roughly half of all ADA website accessibility lawsuits, and 16 firms filed more than 90 percent of them.6EcomBack. Annual ADA Website Accessibility Lawsuit Report
A Los Angeles Times investigation published in April 2026 found that seven regular clients of Orange County’s Manning Law sued more than 1,000 Southern California businesses in a single recent year.5Los Angeles Times. Los Angeles Restaurants Disability Lawsuits7Test Party. The California ADA Shakedown Across Three Law Firms and Their Serial Plaintiffs6EcomBack. Annual ADA Website Accessibility Lawsuit Report
Some of the most prolific filers have faced consequences. Manning Law’s founder, Joseph Manning Jr., had his California law license suspended effective October 2025 after the State Bar found he filed identical, standardized fee declarations in disability rights cases, representing estimated time as actual recorded time. The bar concluded the practice was an act of moral turpitude and imposed a two-year suspension with one year of active suspension.8The Ethics Reporter. Attorney Joseph Richard Manning Jr Suspended for Misleading Billing Practices
Potter Handy, a San Diego firm that once accounted for 85 percent of ADA cases in the Northern District in 2021, was sued in 2022 by the San Francisco and Los Angeles district attorneys, who alleged the firm filed thousands of boilerplate federal ADA lawsuits with fabricated standing allegations — specifically that their clients had personally encountered barriers and intended to return.9CBS News San Francisco. Judge Dismisses San Mateo ADA Lawsuit Serial Filer Brian Whitaker Potter Handy10San Francisco District Attorney. People v Potter Handy LLP Et Al Complaint Brian Whitaker, one of the firm’s most prolific clients with roughly 1,800 federal ADA cases, was sanctioned $35,000 alongside Potter Handy by U.S. District Judge Vince Chhabria for “concerted, bad-faith sanctionable conduct” in a case involving a Peet’s Coffee, with the judge finding “little doubt” Whitaker had no intention of returning when he filed.11Local News Matters. Clear Lies Federal Judge Forces ADA Plaintiff Attorneys to Pay Fine for Bad Faith Lawsuits
Courts can also designate individuals as “vexatious litigants,” which requires a judge’s permission before filing new suits. The Ninth Circuit upheld that remedy against Jarek Molski, who filed roughly 400 ADA lawsuits; the district court found Molski had “plainly lied” about injuries, filing 16 suits in four days alleging identical harm at different establishments.12FindLaw. Molski v Evergreen Dynasty Corp A similar designation was imposed on Peter Strojnik, a former attorney who filed nearly 150 ADA hotel lawsuits before a federal judge barred him from filing new accessibility claims without court approval.13Disability Leave Law. Serial ADA Plaintiff Declared Vexatious Litigant in Federal Court in California
Website Accessibility Cases
Website lawsuits are the fastest-growing segment. California saw 787 website accessibility lawsuits in 2025, a 62 percent increase over 2024, ranking third behind New York and Florida.6EcomBack. Annual ADA Website Accessibility Lawsuit Report Los Angeles County leads the state in digital-access filings.14Darrow Everett. ADA Website Accessibility Litigation Insights Legal Analysis
In the Ninth Circuit, which includes California, courts generally require a “nexus” between a website and a physical business location for the ADA to apply. A California appellate court reinforced this in 2023, holding in Martin v. Thi E-Com., LLC that stand-alone websites without a physical location are not covered by the ADA.15Hoge Fenton. Rise of ADA Drive-By Lawsuits Unruh That ruling collapsed federal website filings in California from 360 in 2021 to just four in 2025.16ADA Title III. Federal Court Website Accessibility Lawsuit Filings Bounce Back The action shifted to state court, where Unruh still applies to websites of businesses with a physical location.
Courts and consent decrees overwhelmingly use the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA as the benchmark for what an accessible website looks like.17American Bar Association. Digital Accessibility Under Title III ADA
One warning for businesses using automated “accessibility overlay” widgets: in April 2025 the Federal Trade Commission ordered accessiBe to pay $1 million for falsely claiming its automated tool could make any website WCAG-compliant. The FTC found the tool frequently failed to make menus, images, and tables accessible.18Federal Trade Commission. FTC Approves Final Order Requiring accessiBe to Pay $1 Million Roughly a quarter of accessibility lawsuits in 2024 targeted companies that were already running overlay products, so those tools do not function as legal cover.19ADA Title III. FTC Orders accessiBe to Pay $1M for Misleading Claims
What a Business Can Do
Get a CASp Inspection Before You’re Sued
California’s Certified Access Specialist (CASp) program, established in 2003 and expanded by Senate Bill 1608 in 2008, lets a business hire a state-certified accessibility professional for a voluntary inspection. The CASp produces a written report identifying violations and a correction schedule. A business holding a CASp report when sued qualifies as a “qualified defendant,” which triggers a 90-day stay of court proceedings and a mandatory early evaluation conference aimed at settling before costs escalate.20City of Oakdale. ADA Compliance The inspection isn’t a guarantee of compliance, and it reflects the property’s status only on the day of the visit, but it can reduce statutory damages to $1,000 per occurrence for qualifying businesses.
Challenge Standing
Federal courts have become more willing to scrutinize whether a plaintiff actually intended to use the business they sued. A growing line of rulings has dismissed cases where judges found the plaintiff’s claim of intending to return not credible, particularly when the plaintiff lives far from the business and has filed hundreds of similar suits.21Jeffer Mangels Butler & Mitchell LLP. How to Defend an ADA or Unruh Lawsuit for Lack of Standing That said, the Ninth Circuit’s 2023 decision in Langer v. Kiser held that a plaintiff’s status as a serial litigant is not, by itself, a reason to doubt their standing, and that courts must take a “broad view” of standing in civil rights cases.15Hoge Fenton. Rise of ADA Drive-By Lawsuits Unruh Standing challenges work when the specific facts support them, not on the plaintiff’s filing count alone.
Invoke the High-Frequency Litigant Rules
Under California Code of Civil Procedure Section 425.55, a plaintiff who files 10 or more construction-related accessibility complaints in a 12-month period is a “high-frequency litigant.” They must disclose their prior filing history and the reason they were in the geographic area of the alleged violation, and they pay an additional $1,000 filing fee in state court.22ADA Title III. Latest California ADA Lawsuit Reform Attempt Watered Down Solution Serial filers have responded by moving cases to federal court, where the state disclosure rules don’t apply, and pairing the federal ADA claim with an Unruh claim to keep the damages available. Some federal courts, including in the Central District, have started declining supplemental jurisdiction over the attached Unruh claims to close that route; ADA filings in that district had grown from 3 percent of the civil docket in 2013 to 24 percent by mid-2019.23Jeffer Mangels Butler & Mitchell LLP. Californias Central District Tries to Curb High-Frequency ADA Litigant Filings
Pending Reforms
Two bills would change the picture significantly if they pass, both built around notice-and-cure: give the business a chance to fix the problem before it can be sued for damages.
California SB 84, introduced by Senator Roger Niello (R-Fair Oaks), would prohibit a plaintiff from suing a business with 50 or fewer employees for construction-related accessibility damages unless the business has first received a letter identifying each alleged violation and been given 120 days to fix them. Corrections within that window would eliminate statutory damages, attorney’s fees, and costs.24LegiScan. SB 84 The bill also blocks plaintiffs from repackaging a physical-access claim as a general discrimination claim to avoid the notice period.25CalMatters Digital Democracy. SB 84 As of mid-2025, it had been amended and re-referred to the Senate Judiciary Committee and had not been signed into law.
The federal ACCESS Act (H.R. 8396), introduced April 21, 2026, by Rep. Ken Calvert (R-CA) with co-sponsors Rep. Jay Obernolte (R-CA), Rep. Lou Correa (D-CA), and Rep. Randy Fine (R-FL), would require written notice of an ADA violation, then give the business 60 days to describe planned improvements and another 60 days to fix the issue or make substantial progress. A lawsuit could proceed only if the business fails to respond or remedy the barrier.26Office of Rep. Ken Calvert. Reps Calvert Obernolte Correa and Fine Introduce Bill to Protect Small Businesses The bill was referred to the House Judiciary Committee and remains pending.27Ripon Advance. Calvert Obernolte Propose Bill to Minimize Meritless ADA Lawsuits
Until either bill becomes law, the Unruh Act’s damages structure remains in place, and California’s ADA docket will keep looking the way it does.