Pennsylvania and Minnesota Website Accessibility Law

Pennsylvania and Minnesota often appear side by side in filing tables, but the two states do not tell the same story. Minnesota filed more federal website cases than Pennsylvania in 2025, and a Minnesota federal court has read websites into public accommodation law in a way no verified Pennsylvania ruling in this research matches. Pennsylvania still matters, because its state law reaches public accommodations, its mid-year 2026 count rose, and its filing pattern runs in bursts rather than a steady stream.

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.

Pennsylvania: the statute and the count

The Pennsylvania Human Relations Act, Act of 1955, P.L. 744, No. 222, codified at 43 P.S. sections 951 to 963, prohibits discrimination in public accommodations, including discrimination because of disability, and it is enforced by the Pennsylvania Human Relations Commission. The Act's public accommodation language is broad, covering the denial of goods, services, facilities, privileges, advantages, and accommodations. The Act does not name websites in the passages reviewed for this draft, so a Pennsylvania website question still runs mainly through the federal ADA route plus the state Act's public accommodation reading, with advice needed on the specific facts.

Seyfarth Shaw counted 137 federal website accessibility lawsuits in Pennsylvania in 2025, against 162 in Minnesota and a national total of 3,117: Seyfarth Shaw 2025 federal website filings

That put Pennsylvania fifth among states in that federal count, behind New York, Florida, Illinois, and Minnesota. The same tracker series shows Pennsylvania at 103 in 2024, so the 2025 figure is a rise, not a fall, even though Pennsylvania slid behind Illinois in rank.

The mid-year 2026 picture from a different tracker points the same way. EcomBack counted 62 Pennsylvania website lawsuits in US courts in the first half of 2026, up from 47 in the first half of 2025, within a national total of 2,045: EcomBack mid-year 2026 report

EcomBack also notes a lumpy Pennsylvania pattern: 21 filings in January 2026, none from February through April, then 40 in June. Check the site on a regular cycle, not after a headline.

Minnesota: the statute, the court reading, and the notice rule

The Minnesota Human Rights Act takes a similar starting point with a different enforcement shape. The Minnesota Department of Human Rights states that businesses open to the public are prohibited from discriminating because of disability, and its public accommodation page points readers to digital accessibility help: Minnesota Human Rights Act public accommodation guidance

In early 2025, a federal district court in Minnesota held that a website can count as a place of public accommodation, reasoning that a website that sells goods functions like a sales establishment for access purposes. A district court ruling is not an appellate ruling, and it does not bind courts outside its district, but it gives Minnesota readers a court reading that Pennsylvania research for this draft did not match. One district decision does not settle Minnesota law for every site, and it says nothing about Pennsylvania.

Minnesota also has a notice rule that is easy to misread. Section 363A.331 requires a person who is an attorney, or is represented by an attorney, to give written notice of an architectural barrier before bringing a civil action over that barrier, and to allow time to remedy it, with at least 60 days in the notice rule: Minnesota Statutes section 363A.331

Read that text closely. It covers architectural barriers that limit access to a business establishment or public accommodation. It is not a general website safe harbor, and this draft does not claim it as one. If a letter about a website arrives, the question whether any notice rule helps depends on the claim as written, and that is a question for an attorney, not a guess from a statute heading.

On counts, Minnesota ran ahead of Pennsylvania in both trackers used here. Seyfarth counted 162 Minnesota federal website filings in 2025. EcomBack counted 120 Minnesota website lawsuits in US courts in the first half of 2026, up from 84 in the first half of 2025. Minnesota also held its place as the most active state outside the traditional leaders in EcomBack's mid-year summary. None of that makes Minnesota a high-volume state on the scale of New York or Florida, but it does make Minnesota the busier of these two states by a clear margin.

What the two counts do not prove

Two cautions apply to both states. First, the trackers count different things. Seyfarth counts identified federal website filings. EcomBack counts website lawsuits in US courts, including state courts in its dataset. The two totals cannot be added together, and a state figure from one tracker cannot be pasted next to a state figure from the other as if they shared a method. This draft keeps each figure with its tracker and its year for that reason.

Second, filing counts leave out demand letters, which never reach a public docket. EcomBack notes that demand letters are especially common in Pennsylvania and never appear in filing totals. No letter figure is quoted here, because none was verified on a primary or named tracker source today.

The Department of Justice position sits behind both states. It 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

What to fix first in either state

Work through the same short list, and keep the report with its date.

• Labels and errors on every form, including checkout, contact, and booking forms. A screen reader user needs a label for each field and a clear note when an entry is wrong.
• Keyboard use across the whole page, including menus, popups, and media players. If the Tab key traps focus or skips content, fix that before any visual polish.
• Alt text for images that carry meaning, and empty treatment for images that are purely decorative.
• Contrast for body text and button text, checked against the background rather than judged by eye.
• Headings in order, so the page can be scanned by headings.

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The scan runs 98 automated checks across 14 fix categories, including 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.

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FAQ

Which state has more website filings, Pennsylvania or Minnesota?

Minnesota, in both trackers used here: 162 against 137 in Seyfarth's 2025 federal count, and 120 against 62 in EcomBack's first half of 2026 count. The trackers count different court sets, so compare within each tracker, not across them.

Does Minnesota's 60-day notice rule give my website a grace period?

Not on the text reviewed here. The rule covers architectural barrier claims and requires notice before a civil action over such a barrier. It does not state a general website grace period. Ask an attorney how it applies to a specific letter.

Can I file a complaint under the state law instead of going to court?

Both states have a civil rights agency route: the Pennsylvania Human Relations Commission for the PHRA, and the Minnesota Department of Human Rights for the Minnesota Human Rights Act. Deadlines and forms differ, so check the agency page for the state in question before filing.

What if a demand letter names faults my scan does not show?

Save the letter, save the scan report with its date, and talk to a qualified attorney. A scan checks automated rules; a letter may cite content, reading order, or other points that need a manual check.

Last checked: October 31, 2026

Sources

• Pennsylvania Human Relations Act compilation
• Seyfarth Shaw 2025 federal website accessibility filings
• EcomBack mid-year 2026 report
• Minnesota Department of Human Rights public accommodation guidance
• Minnesota Statutes section 363A.331
• Minnesota web accessibility law overview
• Department of Justice guidance on web accessibility and the ADA
• Axeazy pricing page
• Axeazy capabilities page

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

Related reading

• New Jersey Website Accessibility and the NJLAD