Domino’s Pizza Accessibility Case Study: The Supreme Court Case

Robles v. Domino’s Pizza LLC is the most high-profile web accessibility case to reach the United States Supreme Court. When the Court declined to hear Domino’s appeal in October 2019, it let stand a Ninth Circuit ruling that the Americans with Disabilities Act applies to websites and mobile apps. The case reinforced the legal framework established by the Target lawsuit and sent a clear message to businesses nationwide. This case study examines the facts, the legal proceedings, and the lasting impact.

The Facts

Guillermo Robles, a blind man who uses screen reading software, attempted to order food from Domino’s Pizza’s website and mobile app. Despite using his screen reader, Robles was unable to complete the order. The website and app lacked the coding structures that screen readers need to interpret and navigate content, including proper labeling of interactive elements, meaningful page structure, and keyboard accessibility.

Robles filed suit in federal court in the Central District of California, alleging that Domino’s violated Title III of the ADA by failing to make its website and mobile app accessible.

Domino’s Defense

Domino’s, supported by a range of business groups including the Restaurant Law Center and the U.S. Chamber of Commerce, raised two primary arguments:

The ADA does not apply to websites. Domino’s argued that when the ADA was passed in 1990, websites did not exist, and therefore the law’s “place of public accommodation” language could not extend to online platforms.

Due process. Domino’s contended that the Department of Justice had never issued specific regulations for website accessibility, and that requiring compliance without clear federal standards violated due process. The company argued it was being held to a standard (WCAG 2.0) that had never been formally adopted by the DOJ as a regulatory requirement.

The Ninth Circuit Decision

On January 15, 2019, the Ninth Circuit Court of Appeals ruled against Domino’s. The court held that:

• The ADA applies to websites and mobile apps that have a connection to a physical place of public accommodation (in this case, Domino’s restaurants).
• The lack of specific DOJ website accessibility regulations does not excuse compliance. The ADA requires businesses to ensure effective communication with disabled customers, and that obligation does not depend on the DOJ issuing technical standards.
• Requiring Domino’s to make its website accessible did not violate due process because the ADA has always required equal access to goods and services.

The Supreme Court Denial

Domino’s petitioned the Supreme Court to hear the case. On October 7, 2019, the Court denied certiorari, meaning it declined to hear the appeal. This was not a ruling on the merits but effectively left the Ninth Circuit’s decision as binding law in the western United States and as persuasive authority nationwide.

The denial was celebrated by disability advocates and viewed with concern by some in the business community who had hoped for a definitive Supreme Court ruling either way. Without a Supreme Court opinion, the legal standards for website accessibility continue to be shaped by circuit courts, creating some variation across jurisdictions.

The Settlement

Following the Supreme Court’s denial, the case returned to the district court. In June 2022, Robles and Domino’s reached a settlement. The terms were not publicly disclosed in detail, but the case had already achieved its most significant impact through the appellate court’s ruling.

Lasting Impact

The Domino’s case produced several enduring effects on web accessibility law:

Validation of ADA applicability. The case confirmed, at the highest-profile level possible short of a Supreme Court opinion, that websites and mobile apps fall under ADA Title III obligations.

WCAG as a de facto standard. Although the court did not mandate WCAG compliance specifically, WCAG 2.0 and 2.1 are now cited in the vast majority of accessibility settlements and consent decrees as the technical standard businesses must meet.

Increased litigation volume. The case contributed to a surge in web accessibility lawsuits. Over 4,000 ADA digital accessibility lawsuits were filed in 2024 alone.

Business community response. Many businesses accelerated their accessibility programs after the Supreme Court denial, recognizing that courts were not going to wait for DOJ regulations before enforcing the ADA online.

For the earlier case that set the stage, see Target accessibility lawsuit case study. For the current litigation landscape, see worst accessibility fails and lessons learned. For the full collection, visit the universal design case studies guide.

Key Takeaways

• Guillermo Robles could not order food from Domino’s website or app using screen reading software due to missing code structure and labeling.
• The Ninth Circuit ruled in 2019 that the ADA applies to websites and apps connected to physical places of public accommodation, and that the absence of specific DOJ regulations does not excuse compliance.
• The Supreme Court denied certiorari in October 2019, leaving the Ninth Circuit ruling in place and sending a strong signal to businesses nationwide.
• The case established WCAG as the de facto technical standard for web accessibility compliance and contributed to the surge in ADA digital lawsuits.

Sources

• https://www.ada.gov/ — U.S. Department of Justice ADA information and guidance on Title III requirements
• https://law.justia.com/cases/federal/appellate-courts/ca9/17-55504/17-55504-2019-01-15.html — Ninth Circuit opinion in Robles v. Domino’s Pizza LLC (2019)
• https://www.supremecourt.gov/orders/courtorders/100719zor_m6io.pdf — Supreme Court denial of certiorari in Domino’s Pizza v. Robles, October 7, 2019
• https://www.w3.org/TR/WCAG20/ — WCAG 2.0 standard cited in the Domino’s case as the de facto technical requirement