As the boundaries between physical and digital business continue to blur, courts are stepping in to clarify what inclusion really means online. One recent ruling, Frost v. Lion Brand Yarn Company, brings that conversation into focus. In February 2025, a Minnesota federal judge ruled that websites qualify as places of public accommodation under ADA Title III. This decision supports what many in the digital and legal communities have long believed: accessibility online deserves consistent attention. While it doesn’t resolve every legal question, it strengthens the case for making digital inclusion part of a responsible business approach.

Frost v. Lion Brand Yarn Company Case

In Frost v. Lion Brand Yarn Company, Clarence and Tammy Frost—both legally blind—alleged that the company’s website was inaccessible to screen reader users. They argued this violated ADA Title III, which prohibits discrimination based on disability in places of public accommodation.

Lion Brand Yarn asked the court to dismiss the case, claiming that its website wasn’t a physical place and therefore didn’t fall under the scope of the ADA.

Court Decision and ADA Title III Interpretation

On February 6, 2025, U.S. District Judge Katherine Menendez denied the motion to dismiss. Her decision stated that a website can, in fact, be considered a place of public accommodation under ADA Title III. She emphasized the law’s broad intent and noted that excluding digital spaces would limit access in today’s online world.

Legal Reasoning Behind ADA Title III Decision

Judge Menendez’s ruling follows a growing trend in how courts interpret the ADA. Even though the law was written before websites existed, many judges now recognize that its goals—ensuring equal access—apply in digital spaces, too.

The court explained that ignoring websites under ADA Title III would go against the law’s purpose. If businesses offer goods and services online, people with disabilities must have equal access to those experiences.

Broader Implications of ADA Title III in Digital Accessibility

This case contributes to the growing conversation about whether ADA Title III covers digital platforms.Some courts have said yes, others no—but momentum is building toward broader interpretation. More judges, and the Department of Justice, are saying that websites count.

By viewing digital platforms as essential for communication and commerce, this ruling helps make the case that online inclusion is part of federal disability rights.

The Legal Shift Toward Website Accessibility Under ADA Title III

The Minnesota decision supports what many businesses and advocates have been saying: websites need to be accessible. While there’s still legal gray area, the trend is clear—courts are treating digital inaccessibility more seriously.

Congress didn’t limit ADA Title III to physical places, and courts are using that flexibility to apply it to today’s technology. With websites acting as digital storefronts, accessibility is increasingly expected as a baseline.

Agencies like the Department of Justice also support this view. As websites become central to how businesses operate, they must be designed with accessibility in mind.

Actionable Steps for Compliance with ADA Title III

If your business operates online, now is the time to prioritize accessibility. Here are some practical, proven steps to move in the right direction:

Conduct Accessibility Audits

Use a mix of automated tools and manual checks to find and fix barriers that prevent access.

Implement WCAG Guidelines

Follow the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA to ensure your content is usable for people with disabilities.

Train Development Teams

Make sure developers and designers understand accessibility best practices from the start.

Engage Users with Disabilities

Include people with disabilities in your testing process—they offer insights that no automated tool can.

Maintain Ongoing Compliance

Use tools like a11y.Radar to monitor your site regularly and stay on top of new issues. Accessibility isn’t a one-time fix—it’s ongoing.

Erkan v. David A. Hidalgo, MD, P.C. provides one example of proactive compliance. There, a judge acknowledged that steps taken to address accessibility concerns helped mitigate legal risk. It’s a good reminder that prevention is always better than response.

Implications of ADA Title III for Businesses

This ruling matters most for businesses that sell or provide services online. Failing to address accessibility could lead to legal challenges, negative press, and missed opportunities to connect with customers.

On the flip side, investing in accessibility shows you value all your users. It can improve user experience, increase brand trust, and even open up new markets.

The Time to Act is Now

The Minnesota ruling strengthens the growing understanding that websites are part of the ADA Title III conversation. While not every legal question is settled, businesses have more reason than ever to take accessibility seriously.

If your website serves the public, this case is a signal to act. Not because you’re forced to—but because it’s the right thing to do.

To learn more about how to proactively address ADA conformance, schedule an ADA briefing with 216digital today. Our team of accessibility experts is ready to guide your business through every step of the process, helping you stay ahead of evolving legal standards while building a more inclusive web for everyone.