It’s been a busy 12 months for Americans With Disabilities litigators across the country, who filed about 15% more digital accessibility lawsuits than they did in 2020—equating to more than 10 lawsuits per day.

And yet, Florida hosted substantially less litigation after the U.S. Court of Appeal for the Eleventh Circuit overturned a landmark ruling in Gil v. Winn-Dixie. In it, the appellate panel found that websites generally aren’t covered by the ADA, Title III of which governs accessibility of public spaces and prohibits discrimination on the basis of disability.

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