Georgia and Ohio Website Accessibility Law

Georgia and Ohio are often grouped as quiet states for website cases, and the filing data supports the word quiet, with a limit that matters. In the tracker used here, neither state appears in the 2025 federal per-state list at all. That is a real data point, not a verdict that sites in either state face no attention. Georgia and Ohio also differ in law in a way a single "quiet state" label hides: Georgia's most quoted appellate ruling on websites no longer stands, while Ohio has its own civil rights statute and a notice rule that change how an accessibility claim can proceed.

This is general information, not legal advice. If you received a demand letter or were sued, talk to a qualified attorney, and take your scan report and fix record to that meeting.

Georgia: the ruling that no longer stands

Georgia sits in the Eleventh Circuit, which covers Alabama, Florida, and Georgia. In April 2021, a three-judge panel of that court held that websites are not places of public accommodation under ADA Title III, and it rejected the nexus standard that other circuits use to link a website to a physical place. The panel also stressed that the website in that case was limited use and not a point of sale, since purchases had to occur in the store, which left open how a court might treat a website that sells directly.

That panel ruling is widely quoted, and quoting it without its ending misleads readers. The ruling was later vacated as moot on December 28, 2021, and it binds no court. The Eleventh Circuit therefore has no controlling website accessibility holding from that case. A Georgia owner who relies on the 2021 panel ruling as settled law is relying on a ruling that was taken off the books: circuit split summary on the vacated ruling

What remains for Georgia readers is a split picture. The Department of Justice has consistently taken the position that ADA requirements apply to the goods, services, privileges, or activities offered by public accommodations, including those offered on the web: ADA guidance on web accessibility

Other circuits read the website question differently, and district courts in the Eleventh Circuit still have to apply the law to each site's facts, including whether the site sells online or stands alone. Georgia's filing picture does not resolve that tension.

No Georgia state website filing count or damage figure is quoted here, because none was verified on a primary state source today.

Ohio: its own statute and its own notice rule

Ohio's starting point is clearer on paper than Georgia's, because Ohio has a civil rights statute that names public accommodation discrimination directly. Section 4112.02(G) of the Ohio Revised Code makes it an unlawful discriminatory practice for a proprietor, employee, keeper, or manager of a place of public accommodation to deny any person, except for reasons applicable alike to all persons regardless of disability, the full enjoyment of the accommodations, advantages, facilities, or privileges of that place: Ohio Revised Code section 4112.02

Section 4112.01 defines a place of public accommodation to include an inn, restaurant, eating house, barbershop, public conveyance, theater, store, other place for the sale of merchandise, or any other place of public accommodation or amusement whose advantages are available to the public. Like the other state texts in this series, the definition lists physical places and does not name websites. An Ohio website question therefore still turns on how a court reads that definition for a business whose services run through a site, and on the federal ADA route alongside it.

Ohio adds a procedure that Georgia readers do not have in the same form. Under section 4112.16, a person who plans a civil action alleging violation of an accessibility law may notify the owner, agent, or other responsible party before filing. If no notice is served, the person is generally not entitled to attorney fees on a judgment in such an action, unless the trial court determines that fees are appropriate. That rule gives an Ohio owner a concrete reason to act on a notice at once and to keep a dated record of fixes. It does not state a general website grace period, and this draft does not claim one.

Ohio also has a Civil Rights Commission route for charges of discrimination, separate from a court filing. Check the Commission's own pages for deadlines and forms before any filing.

The filing picture for both states

Seyfarth Shaw counted 3,117 federal website accessibility lawsuits in 2025, up 27 percent from 2,452 in 2024: Seyfarth Shaw 2025 federal website filings

The published per-state list for 2025 names 12 jurisdictions, and those 12 figures add to the full 3,117 total. Neither Georgia nor Ohio appears in that list. The fair reading is narrow: in Seyfarth's identified federal count for 2025, no Georgia or Ohio website filing was listed. It is not a finding that no Georgia or Ohio business received a letter, faced a state court case, or drew a complaint, because Seyfarth counts identified federal filings only, and its method notes that some cases may be missed if their descriptions lack the search keywords.

A second tracker groups both states out of sight in a different way. EcomBack's mid-year 2026 report lists Illinois, California, New York, Florida, Minnesota, Indiana, and Pennsylvania by name, and puts every other state together in an "All Other States" total of 139 website lawsuits in US courts in the first half of 2026. Georgia and Ohio sit inside that combined total, and no split for either state can be read from it. This draft therefore gives no mid-year figure for either state, rather than inventing a split.

What to fix first in Georgia and Ohio

Use the Justice Department barrier list as the checklist, and start with the paths visitors use to buy, book, or contact you.

• Labels and error notes on every form, including checkout, booking, and contact forms. Placeholder text inside a box is not a label.
• Keyboard use across the full page, including menus, popups, and media players. If focus gets trapped or vanishes, fix that first.
• Short alt text for images that carry meaning, and empty treatment for decorative images.
• Contrast for body text and button text against their backgrounds.
• Headings in order, so the page can be scanned by headings.

Axeazy offers a free homepage scan that takes about 60 seconds, with no signup and no card, and paid plans show price at checkout with annual saving of 20 to 25 percent: Axeazy pricing

The scan runs 98 automated checks across 14 fix categories, including alt text, form labels, link names, button names, keyboard tab order, and heading structure: Axeazy capabilities

For sites with a code repository, fixes arrive as a real pull request with a visible diff, reviewed and merged by the site owner or developer. For WordPress, a free plugin applies 3 instant render-time fixes. For Shopify, owners receive a guided plain English checklist. Colour contrast is detected and a correct colour is calculated, but a visible colour change is never applied without owner approval.

For a structured way to compare tools, see how to choose an accessibility tool, 10 criteria and best accessibility tools for small business

FAQ

Does the 2021 Eleventh Circuit ruling protect Georgia websites?

No, not as a settled holding. The panel ruling was later vacated as moot and binds no court. Georgia website questions still turn on each site's facts, the Justice Department position, and advice from a qualified attorney.

Does Ohio's notice rule give my site a grace period?

Not in general terms. Section 4112.16 addresses notice before a civil action over an accessibility law violation and the fee consequence when notice is not served. It does not state a website grace period. Act on any notice promptly and keep a dated fix record.

If neither state shows federal filings in 2025, can I skip accessibility work?

No. The tracker counts identified federal filings only. Letters, state cases, and complaints sit outside it, and a quiet year in one tracker does not change the barrier list or the state statutes described above.

What should I keep if a letter arrives?

Keep the letter, its date, and any envelope or email headers. Run a scan, save the report with its date, log each fix with its date, and talk to a qualified attorney before replying.

Last checked: October 31, 2026

Sources

• Circuit split summary on the vacated Eleventh Circuit ruling
• Department of Justice guidance on web accessibility and the ADA
• Ohio Revised Code section 4112.02
• Ohio Revised Code section 4112.01
• Ohio Revised Code section 4112.16
• Seyfarth Shaw 2025 federal website accessibility filings
• Axeazy pricing page
• Axeazy capabilities page

For a dated starting record, run the free scan from Axeazy

Related reading

• Website Accessibility Lawsuit Statistics for 2026