Running Head: WEBSITES AS PLACES

Websites as Places: The ADA, Title III, and Newer Media

Sheryl Chaisson
Rutgers University

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Introduction
Tasha is twenty-five years old and lives alone. While she does not suffer from complete
blindness, she does have very low vision. Tasha has been able to establish a mostly independent
life despite her visual impairment. She still relies on her family members and friends for rides to
accomplish such routine tasks as doctor visits and grocery shopping. She learns about a website
that would allow her to order groceries online and have them delivered right to her door. Tasha
becomes excited at the prospect of relying on other people less, especially for such a common
task as buying groceries. She gets on her computer, for which she uses a screen reader that
generates audio to read the text on the screen to the user. Tasha logs on to the website offering
the grocery delivery service. To her confusion, she keeps hearing things like header.png, and
space.gif. She never hears anything that sounds like a menu or options to learn about the items
she can buy. Tasha realizes that the only way she would be able to use the site is with someone
else present to guide her through it. Frustrated, she logs off of the website.
The story of Tasha illustrates just one example of how site incompatibility with
accessibility devices can lead to a users inability to use the site well or at all. Screen readers,
such as the one used by Tasha in the story, rely on a website to use text labels in what are known
as HTML Alt tags for images and multimedia elements (Lynch 2004; Russell 2003). Both
Android and Apple tablets have audio-generating features for the visually impaired that also rely
on text elements (Wahlbin 2012; Wahlbin 2013). A report done by The National Center for the
Research and Dissemination of Disability Research found that the webs morphing into a
multimedia interface, which includes elements such as images, tables, animation, page frames, or
Flash, has consequently also led to limited experiences by users with disabilities who use such
devices as screen readers (Lynch 2004; Sanchez 2012). The frequently used file format of PDF

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to present text is often also incompatible with accessibility devices (Russell 2003).
Individuals with visual impairments are also able to use a technology that creates a
refreshable display of Braille to translate to the reader what is on the screen (Russell 2003).
Some individuals with low vision do not need additional devices or software, but do need a site
with text that enlarges easily and design with contrasting colors for easier legibility (Newton
2010). Sites that require heavy mouse use with no keyboard alternatives also create an issue due
to the difficulty of an individuals seeing the cursor at times. The reliance on a mouse creates an
additional obstacle for those with physical or motility disabilities. Finally, individuals with
hearing impairments are not able to access sites with multimedia that rely heavily on things like
audio instructions and no captioning or subtitles (Russell 2003). Video clips with no
accompanying text are also inaccessible to them. Some website designers are simply unaware
that their creations generate such a hindrance for individuals, while others such as online
games -- intentionally disable accessibility options to ward off cheating (Lynch 2004; Newton
2010). Some argue that certain services have phone options, though advocates for accessibility
note that phone alternatives, such as those for plane tickets, often lack comparable deals and
specials that websites offer (Haggman 2002).
The present paper explores the arguments for and against requiring that websites be
accessible to individuals with disabilities. Much debate on the issue involves different
interpretations of Title III of the Americans with Disabilities Act. Discussions have also raised
concerns with the First Amendment and the notion of forced or compelled speech. After
exploring these arguments, the paper presents recommendations for future legislation on the
matter.
Background

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Americans with Disabilities Act. In 1990, President George H. W. Bush signed the
Americans with Disabilities Act into law; Congress intended for the legislation, often referred to
by its abbreviated title as ADA, to preclude discrimination against individuals with disabilities
(Introduction to the ADA, n.d.). The act contains provisions to ensure that individuals with
disabilities have the same opportunities as everyone else to participate in the mainstream of
American life (para. 1). The Americans with Disabilities Act (1991) defines the term
disability as:
(A) a physical or mental impairment that substantially limits one or more major life
activities of such individual;
(B) a record of such an impairment; or
(C) being regarded as having such an impairment (12102, 1).
In a Findings segment, the Americans with Disabilities Act (1991) states that Congress
had documented evidence that exclusion of disabled individuals in various societal aspects
caused these individuals to occupy an inferior status in our society, and [be] severely
disadvantaged socially, vocationally, economically, and educationally (12101, a). The section
additionally stresses that individuals with disabilities had no legal opportunities by which to
address and fight such injurious exclusion before the act was passed. Congress further explains
in this section its intention to rectify this lack of needed legal recourse with the proposed statute
as well as to charge the federal government with enforcing it, most notably through invocation of
the Fourteenth Amendment and commerce regulation.
While the ADA contains multiple titles, the one most often cited and discussed when
addressing newer media and accessibility requirements is Title III, which details requirements
for Public Accommodations and Services Operated by Private Entities (Americans with

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Disabilities Act 1991). It defines private entity, rather simply, as an entity that is not public.
The statute enumerates various entities that are considered public accommodation when
commerce is involved. The extensive list of qualifying public accommodation entities includes
places for entertainment, recreation, education, and other services. Newton (2010) explains that
when addressing matters of newer technology, such as websites, courts have had to decide
whether or not the entitys commerce activities must occur in a physical building in order for
Title III to apply. Unfortunately, such cases have also resulted in a circuit split. While courts in
the First, Second, and Seventh Circuits do not see physical structure as a requirement for Title III
application, those in the Third, Sixth, Ninth, and Eleventh Circuits do. Thus, no consensus yet
exists on the necessity, or lack thereof, of a physical structure that houses an entitys transactions
with regard to Title III of the ADA.
Current newer media accessibility legislation. While the ADA makes no explicit
provisions for newer media and non-physical entities, some statutes have recently been enacted
to directly address accessibility with novel technology. President Obama signed into law the
Twenty-First Century Communications and Video Accessibility Act in 2010 (Malmgren, 2010).
The act serves as an update to the Communications Act of 1934. Referred to as the
Accessibility Act, it requires new services such as Voice over Internet Protocol software to
accommodate for deaf or hard-of-hearing individuals. With regard to online video, the
Accessibility Act expands the number of online shows that have closed captioning and requires
that the FCC make recommendations for the best way to make audible explanations of both
onscreen content and video menus available, thus allowing for individuals with visual
impairments to better enjoy more online television programming. The FCCs recommendations
went into effect in March of 2012 and stipulate that the captioning rule applies only to full-length

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videos that also aired on television with closed captioning (Greater Los Angeles on Deafness v.
CNN 2013). The regulation also grants the FCC jurisdiction over complaints and violations of
the rule.
In 1998, Congress amended the Rehabilitation Act of 1973 with Section 508, mandating
that federal agencies work to ensure that individuals with disabilities are able to access their
websites and electronic services with an experience as similar to that of a non-disabled user as
possible (Lynch 2004; Russell 2003). Section 504 of the Rehabilitation Act, in conjunction with
Title II of the ADA, has also been used to expand this accessibility requirement to local and state
agencies receiving federal funds.
Key cases. While multiple cases have been brought before courts that addressed issues
of the ADA and its application to the Internet, most have either settled out of court or were
dismissed (Haggman 2002; Newton 2010). The cases that have been granted rulings are thus far
contradictory in the courts interpretations of Title IIIs application to the Internet. The 2002
court case Access Now, Inc. v. Southwest Airlines Co. served as the first true test for this debate
in a courtroom (Haggman 2002; Newton 2010). A district court in Miami ruled that Title III did
not apply to a companys website. While the case made it to an Eleventh Circuit Court of
Appeals, it was dismissed after the plaintiffs changed their argument; the district courts ruling
stood.
Ten years later, a federal court in Massachusetts (in the First Circuit) found that a place
of public accommodation does not have to be physical in nature and could include the Internet
in National Association for the Deaf v. Netflix (Sanchez 2012). That same year, a district court
in California granted Netflixs request for dismissal in Cullen v. Netflix (2012), citing Ninth
Circuit precedent that a place of public accommodation needed to be physical in nature and the

WEBSITES AS PLACES

Internet did not qualify. The fact that these two cases occurred in the same year and involved the
same company yet still yielded different rulings illustrates a need for clarification on Title IIIs
relation to the Internet by either the Supreme Court or Congress.
The Department of Justice (DOJ) settled its first lawsuit regarding the ADA and the
Internet in 2014 with the case of National Federation of the Blind, et. al. & U.S. v. HRB Digital
LLC, et al (Soltis 2014). The Department of Justice found that Title III does indeed apply to the
Internet and even mobile applications. The defendant, H&R Block, was ordered to make its site
and app related to its tax preparation services accessible as outlined in the Web Content
Accessibility Guidelines 2.0. While advocates for Title IIIs application to the Internet may see
the ruling as a sign that the debate is over, it is important to note that the DOJ has been
advocating for applying Title III to the Internet since 1996 (Lynch 2004). Not only did the DOJ
issue an advisory letter that the ADA should include the Internet, but it also submitted an amicus
brief for a Fifth Circuit case related to the issue. Despite the DOJs clear position, the debate on
the ADA and the Internet has persisted.
Title III and Place: Physical versus Non-physical
As discussed in the Background section of this paper, a key debate on the application of
the ADA, specifically Title III, is what defines a place with regard to place of public
accommodation. This section explores the circuit split of precedents on the matter in addition
to arguments from both sides.
Physical structure requirement for public accommodation.

In 1995, the Sixth

Circuit ruled that a place must be a facility in Stoutenborough v. National Football League, Inc
(Newton 2010). The plaintiff used Title III of the ADA to claim that the blackout on television
of NFL games that did not sell out but not on radio discriminated against individuals with

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hearing impairments. The court conceded that while a physical place the football stadium -was involved, that was not sufficient grounds for a violation of Title III. The circuit ruled again
in favor of the necessity of physical structures when defining place of public accommodation
in Parker v. Metropolitan Life Insurance Co. The case involved a life insurance policy offered
through the plaintiffs employer. The court found that Title III would not be applicable because
the insurance policy, though a service mentioned in Title III, was not offered through an actual
building or office belonging to the business. Had the policy transaction occurred in a branch or
office belonging to Metropolitan Life Insurance, the plaintiff may have had grounds to claim
Title III violation. With this ruling, the court also established the nexus test of a service or
transaction with a physical structure. The Third and Ninth Circuits adopted the nexus test in
rulings that were, incidentally, also about insurance policies: Ford v. Shering-Plough Corp and
Weyer v. Twentieth Century Fox Film Corp., respectively. In Cullen v. Netflix (2012), the court
cited the Ninth Circuit precedent in Weyer of defining a place as a physical structure or the
services having a nexus to one.
Julian Sanchez (2012) argues that the Internet and websites should not be considered
places. Sanchez says the Internet is less a place and more streams of information (para. 6). He
continues by noting that the only physical aspects of the Internet are the servers on which
websites are stored: servers that are not part of the average end users Internet experience.
Sanchez also emphasizes that the end users experience with a website is not completely
determined by the designer. He explains that a users browser and computer settings join the
sites coding as factors that affect a websites appearance. Sanchez contrasts this collaborative
process with physical buildings, noting that only owners of buildings can make such accessibility
changes to the structures such as wheelchair ramps; visitors or customers of the building

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cannot (para. 11). Sanchez also argues that websites are structures consisting of speech and are
content more than anything else.
A more nuanced nexus. The Eleventh Circuit set a different nexus precedent with the
case Rendon v. Valleycrest Productions, Ltd. (Newton 2010). The plaintiff accused the
television program Who Wants to be a Millionaire? of discriminating against individuals with
hearing and mobility impairments. The game show involved a telephone screening process that
asked potential contestants questions and required them to key in the answer with a phones
touchpad. The plaintiff argued the lack of accessibility violated Title III of the ADA. A district
court dismissed the case on grounds that it did not involve an actual place. An Eleventh Circuit
Court of Appeals, however, reversed the lower courts decision. The rationale was that the
theater in which the game show was held was a physical structure and, thus, a place; the phone
screening was considered a means of accessing the place. This created the necessary nexus for a
discrimination trial to proceed. It also established that both barriers that are tangible and those
that are not might be covered under the ADA (Haggman 2002).
As mentioned in the Key Cases subsection of this paper, many cases involving the
ADA and the Internet have been settled out of court or dismissed with no precedents created.
While such is the case with National Federation for the Blind v. Target Corp., scholars have still
extrapolated important interpretations about Title III (Newton 2010). The plaintiff claimed that
Targets website was not accessible due to its incompatibility with screen readers. A district
court in the Ninth Circuit allowed the case to proceed by utilizing the nexus test to establish offsite discrimination, even though the website was not connected to a solitary physical structure
(197). As Newton explains, scholars still use the case as an example of a flexible nexus to a
physical structure even though no official precedent was set.

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Non-physical places. The case of Carparts Distribution Center, Inc. v. Automotive

Wholesalers Association of New England in 1994 set the First Circuits precedent, which would
later be upheld in National Association for the Deaf v. Netflix, that a place need not have
physical characteristics (Newton 2010). The court found that mail or phone businesses that
offered services enumerated by the ADAs Title III as a place of public accommodation were
still just as accountable for providing accessibility accommodations as their brick-and-mortar
parallels. The court classified the business in this particular case as a travel service, something
explicitly mentioned in Title III. The Second Circuit followed this precedent in Pallozzi v.
Allstate Life Insurance Co., as did the Seventh Circuit with Doe v. Mutual of Omaha Insurance
Co. The court in the latter case noted that a place can be electronic in nature just as it can be
physical. These circuits also seem to agree that there is a difference between requiring places
to provide people with disabilities access to their products or services, and requiring [them] to
fundamentally alter their products or services to accommodate people with disabilities (193).
Scholar William Lynch (2004) approaches the ADA and Title III with a statutory
interpretation to argue that a place of public accommodation can be non-physical. He notes
that the word place has seventeen different dictionary definitions, which range from
classifying the term with boundaries that are definite to those that are not. While the ADA is
specific in the examples of places it lists, it is also inclusive and exhaustive with terms at the end
of each example, such as other place of exhibition or other place of public gathering (253).
Lynch argues that this leaves room for the Internet and its websites. Additionally, he proposes
that the Internet could easily be classified as one of the specified establishments or services,
including sales or rental, public display, public gathering, recreation, and education. Finally,
Lynch draws attention to the definition of discrimination in the Americans with Disabilities Act

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(1991): a failure to remove architectural barriers, and communication barriers that are structural
in naturewhere such removal is readily achievable ( 12182 (b)(2)(A)(iv)). Communication
barriers are not limited to the physical world, thus non-physical places may be included (Lynch
2004).
Congressional intent. Debates and discussions of physical versus non-physical
requirement for the ADA and Title III often move beyond the denotation of place and to
congressional intent. Those who wish to define place with a physical requirement argue that
Congress never intended for the Internet, which was in its infancy at the time, to be included
(Haggman 2002). Sanchez (2012) notes that even if the Internet were too novel a technology to
consider for the ADA in 1990, Congress would have explicitly added it when they extensively
amended the statute in 2008. Advocates for inclusion of the Internet under the ADA note that
the statutes jurisdiction is based upon Congress ability to regulate interstate commerce; thus
any discrimination in interstate commerce, which could include the Internet, may be regulated
(Newton 2010).
Lynch (2004), another advocate for including the Internet under the ADA, addresses the
exclusion of the Internet in the statute and congressional intent. He argues that one must not
focus on the exclusion of the medium but instead on the fact that Congress would have explicitly
noted that non-physical places were exempt from the statute if they had so intended. Lynch
notes that the impetus for Congress when drafting the Americans with Disabilities Act was their
concern with economic effects of discrimination in such contexts as places of education, public
accommodation, and communication. He argues that all three types of places may be applied to
the Internet.
While the Supreme Court has yet to rule on the ADA and its application to the Internet, it

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interpreted the ADA as elastic enough to cover situations not specifically mentioned in the
statute in Pennsylvania Department of Corrections v. Yeskey (Lynch 2004). In a unanimous
decision that expanded the application of Title II of the ADA, the court ruled, the fact that a
statute can be applied in situations not expressly anticipated by Congress does not demonstrate
ambiguity. It demonstrates breadth (255). Title II, which applies to government agencies and
services, was also used in Vincent Martin, et. al. v. Metropolitan Atlanta Rapid Transit Authority
to require a services schedules be in an accessible format on its website (Russell 2003).

These

two cases demonstrate that Title III of the ADA could be expanded to include the Internet and
websites if needed.
First Amendment Concerns
Critics of the extension of Title III to websites cite First Amendment concerns in addition
to their arguments that websites are not places (Sanchez 2012). These critics believe that website
coding and design are forms of expressive speech. They also hold that the requirements of Alt
tags in coding or links to text-only versions of a website would be forced speech (Lynch 2004).
This forced speech would also create a forced reallocation of resources to making a website
accessible instead of putting them towards other site choices and improvements. This
reallocation of resources would especially be seen in sites that are completely done with Flash,
which would have to go through extensive redesigning; this burden may prove very hard for
smaller websites and companies (Sanchez 2012). Some see websites as content producers rather
than places.
In Greater Los Angeles Agency on Deafness, Inc. v. CNN (2013), the defendant argued
that forced captioning of online video violated the First Amendment as it affected the
organizations editorial freedom and burdened its speech. CNN stated that if they were required

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to have captions on all videos, this would delay their ability to post news content when they
wanted. Additionally, they felt that having to use an automatic transcription service, which was
often faulty, was the equivalent of forcing them to publish error-laden content. A Ninth Circuit
Court of Appeals, however, ruled that First Amendment rights could be burdened if there were a
benefit to public interest; thus, a captioning requirement would not impinge upon CNNs
constitutional rights. While the court ultimately deferred the decision on discrimination in the
case to the California Supreme Court, its ruling and opinion with regard to the First Amendment
is an important point in justifying accessibility requirements that could be seen as forced speech.
Like the court in the CNN case, Lynch (2004) argues that accessibility accommodations
would be justified even if they somehow affected freedom of speech. Lynch invokes the opinion
of the Supreme Courts ruling in U.S. v. OBrien, which provided a test for when congressional
regulation is justified with regard to potential First Amendment right violations. The Court
found that the governmental interest [must be] unrelated to the suppression of free expression,
which Lynch believes accessibility accommodations would be as they involve eliminating
discrimination and are not related to the actual content of websites (259). Lynch concludes that
if Title III were expanded to cover the Internet, it would still pass constitutional scrutiny. As he
notes, Title III does not prohibit speech, it amplifies it (263).
Evidence of public interest and justification for any potential limiting of freedom of
speech and expression incurred by imposing accessibility accommodations is apparent in the
increasing utility of the Internet in routine and daily life (Lynch 2004). Catherine Russell (2003)
states that accessibility benefits of such services as online banking and online shopping are selfevident. She continues by noting that technologys presence in the essential functions of the
workplace has also grown significantly. Accommodations of these technologies for individuals

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with disabilities would create equal access as well as equal opportunities. The most recent
Census estimates that around 56.7 million Americans have a disability almost 20% of the
population (Nearly 1 in 5 2012). Regardless of the expressive rights argument against
requiring certain sites to meet accessibility standards, regulation that fights discrimination
against one-fifth of the countrys citizens would be a matter of public interest and justifiable.
Recommendations for Future Legislation
The easiest and most obvious resolutions to the ongoing debate of Title IIIs applicability
to the Internet would be for either the Supreme Court to settle the circuit split or Congress to
amend the Americans with Disabilities Act to explicitly state whether or not websites should be
included. An additional option would be to draft and enact separate legislation that would fill in
holes of accessibility similar to the Accessibility Act of 2010 that requires closed captioning for
certain videos and services. Should Congress draft an amendment to Title III or a new piece of
legislation, the present paper recommends certain provisions.
The first provision would require commercial websites to be accessible in the following
ways: text labels to allow for compatibility with screen readers and Braille devices, videos with
captioning or substantial textual explanation, audio instructions with text alternatives, and
keyboard alternatives for individuals with difficulty using a computer mouse. Commercial
websites would be defined as websites with characteristics that mirror entities enumerated in the
ADAs Title III in addition to websites with substantial profit. In other words, websites such as
Facebook that make money from advertising revenue would be required to be accessible
provided its profits were high enough. It is beyond the ability of this paper and its author to
deem a minimum level for profit; however, the intention is to prevent a website that is arguably a
business from the ability to discriminate when a brick-and-mortar business that might take in less

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funds cannot. This provision is also intended to avoid infringing upon websites such as blogs
that are mere hobbies or platforms for their creators.
The second provision would be that all online job applications, no matter the industry
classification, be accessible. This proposed stipulation would prevent job applications for certain
organizations from exclusion should they not apply under Title II or Title III. The third
provision would stipulate a delay of two years before the preceding provisions took effect,
allowing sites to become compliant and providing safe harbor from any litigation they might
otherwise incur. Critics of the application of Title III to websites expressed concern that
expanded accessibility requirements would result in a flood of lawsuits; the provisional delay
would help avoid this and give websites a safe harbor until they are able to become compliant
(Sanchez 2012; Haggman 2002). The same critics also argue that creating an accessible site
could prove burdensome to smaller entities on the Internet; however, not all websites are
included due to the first provision, and plenty of free resources exist to help with accessibility
(Lynch 2004; Russell 2003).
The preceding recommendations for accessibility requirements on the Internet should
survive constitutional scrutiny. They are a reasonable extension of the Americans with
Disability Act, which has already had its Title II provisions extended to apply to the Internet in a
similar fashion. Additionally, some circuits would argue that physical structure was never a
requirement for a place of public accommodation; thus, it is a mere matter of interpreting the
ADA. The statute itself is based on Congress constitutional power to regulate interstate
commerce. The public interest in accessibility regulations and content-neutral nature of such
regulations also serve to quell First Amendment concerns, allowing the provisions to pass
constitutional scrutiny on those grounds.

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The implications of the Findings section of the Americans with Disability Act are no
less true today than they were in the late twentieth century. Discrimination can leave citizens
with disabilities with an inferior status and disadvantages socially, vocationally, economically,
and educationally. As society changes, so does the daily life of the average citizen: services and
industries, even activities such as socializing, are moving to the online realm (Lynch 2004;
Russell 2003). Accessibility barriers today are new and different than the ones Congress had in
mind when drafting the Americans with Disabilities Act. Their novelty, however, is not reason
enough to permit their continued existence.

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References

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