If you have received an ADA website accessibility lawsuit in 2025, there is a significant chance it came from one law firm: Manning Law, APC. Based in Newport Beach, California, Manning Law has become the dominant force in ADA digital accessibility litigation, filing an estimated 280+ federal lawsuits in just the first six months of 2025.
This represents approximately 14% of ALL ADA website accessibility lawsuits filed nationally during that period. When combined with their California state court filings under the Unruh Civil Rights Act, their total impact is even larger.
For government entities, e-commerce businesses, and organizations across the country, understanding Manning Law's litigation strategy is not optional. It is essential for risk management. This analysis examines their filing patterns, top plaintiffs, targeting methodology, and the defense strategies that have proven effective against their claims.
Who Is Manning Law, APC?
Manning Law, APC is a Newport Beach, California-based law firm that has specialized in disability rights litigation, particularly ADA website accessibility cases. The firm gained national prominence through the landmark *Robles v. Domino's Pizza* case, which established that websites and mobile apps of businesses with physical locations must be accessible under the ADA.
The Robles v. Domino's Legacy:
In 2019, the Ninth Circuit Court of Appeals ruled in favor of Guillermo Robles, a blind man who could not order pizza through Domino's website or mobile app using screen reader software. The court held that Domino's had violated Title III of the ADA by failing to make its digital platforms accessible.
This ruling was pivotal because:
• It established that ADA Title III applies to websites and mobile apps
• It rejected Domino's argument that lack of DOJ technical standards was a defense
• It created precedent used in thousands of subsequent lawsuits
• It made Manning Law the go-to firm for ADA digital accessibility claims
Current Operations:
Manning Law now operates what critics call an industrial-scale litigation practice, filing complaints across multiple jurisdictions on behalf of a relatively small number of repeat plaintiffs. Their California base allows them to leverage the state's Unruh Civil Rights Act, which provides $4,000 minimum statutory damages per violation, plus attorney fees.
Important Context:
While critics characterize some of these lawsuits as exploitative, it is worth noting that genuine accessibility barriers do harm people with disabilities. Many websites sued by Manning Law plaintiffs genuinely fail to work with screen readers, keyboard navigation, or other assistive technologies. The debate centers not on whether accessibility matters, but on the methods and economics of enforcement.
Manning Law's Top Plaintiffs: The Names Behind the Lawsuits
One of the most striking aspects of ADA website litigation is its concentration among a small number of serial plaintiffs. Manning Law represents several of the most prolific filers nationally:
H1 2025 Filing Leaders (Manning Law Plaintiffs):
• Michael Sandoval: 114 lawsuits (5.66% of all cases)
• Perla Mageno: 55 lawsuits (2.73%)
• Rebecca Castillo: 52 lawsuits (2.58%)
• Other Manning Law plaintiffs: 59+ lawsuits (~3%)
Total Manning Law plaintiffs: 280+ cases (14%+ of national filings)
The Serial Plaintiff Model:
These plaintiffs typically:
• Are individuals with visual impairments who use screen readers
• Systematically test hundreds or thousands of websites for violations
• File complaints when they encounter barriers
• Seek settlements rather than prolonged litigation
• Generate income through settlement payments and statutory damages
Settlement Economics:
The typical Manning Law case settlement structure includes:
• Plaintiff damages: $4,000-$12,000 (California Unruh Act minimum)
• Attorney fees: $15,000-$35,000
• Injunctive relief: Website must be made accessible
• Total defendant cost: $25,000-$60,000+ (plus remediation)
Why This Matters:
Understanding that a small group of plaintiffs drives the majority of litigation helps organizations assess their risk. If your website has obvious accessibility barriers (missing alt text, keyboard traps, inaccessible forms), you are essentially waiting to be discovered by systematic scanning operations.
See complete plaintiff concentration analysis for the full picture of who files these lawsuits.
How Manning Law Selects Targets
Manning Law plaintiffs do not randomly encounter inaccessible websites. They employ systematic methods to identify defendants with the highest combination of accessibility violations and settlement capacity:
Step 1: Automated Scanning
• Use automated tools to scan thousands of websites for WCAG violations
• Identify obvious failures: missing alt text, color contrast issues, form labels
• Prioritize sites with high violation counts
Step 2: Manual Verification
• Test flagged websites with actual screen reader software (JAWS, NVDA, VoiceOver)
• Document specific barriers encountered during attempted use
• Create evidence of inability to complete transactions or access information
Step 3: Target Selection Criteria
• California nexus: Can the business be sued under California Unruh Act? ($4,000+ damages)
• Settlement capacity: Does the business have resources to settle?
• Clear violations: Are barriers obvious and easily documented?
• E-commerce focus: Payment systems and shopping functionality
Step 4: Demand Letter or Lawsuit
• Some cases begin with pre-litigation demand letters
• Others file directly in federal court or California state court
• Complaints follow standardized templates with specific violations listed
Industries Most Targeted:
Based on 2025 filing data, Manning Law plaintiffs disproportionately target:
• E-commerce and retail (69% of cases)
• Restaurants and food delivery (30% of e-commerce subset)
• Travel and hospitality
• Professional services with online booking
• Government entities (increasingly)
Geographic Patterns:
While Manning Law is California-based, they file nationally:
• California state court (Unruh Act cases)
• Federal courts in California, Arizona, Nevada
• Expanding to Texas, Florida, and other jurisdictions
• Some plaintiffs establish residency claims in multiple states
Check If Your Website Is a Target
Manning Law plaintiffs use automated scanning to find websites with obvious violations. Our free scanner checks for the same WCAG issues they target. Find out if your site has the violations that attract serial plaintiff attention.
Scan Your Website NowDefense Strategies Against Manning Law Claims
If you receive a lawsuit or demand letter from Manning Law, your response strategy matters significantly. Here are approaches that have proven effective:
IMMEDIATE ACTIONS (Days 1-7):
1. Do NOT Ignore the Complaint
• Federal complaints require response within 21 days
• Ignoring leads to default judgment
• Even meritless claims require formal response
2. Hire Experienced ADA Defense Counsel
• General business attorneys often lack ADA expertise
• Experienced ADA defense attorneys know Manning Law's patterns
• They understand settlement ranges and litigation tactics
• Recommended: JMBM, Seyfarth Shaw, or other ADA-focused firms
3. Preserve Evidence
• Document current website state (screenshots, recordings)
• Gather any existing accessibility efforts documentation
• Identify when violations were introduced
• Preserve communications about accessibility
DEFENSE STRATEGIES:
Standing Challenges:
• Did the plaintiff actually visit/attempt to use your website?
• Can they demonstrate intent to return?
• Post-*Acheson v. Laufer* (2023), standing requirements are stricter
• Some courts dismiss cases where plaintiff cannot prove genuine injury
Good Faith Defense:
• Document all accessibility improvement efforts
• Show compliance timeline and progress
• Courts consider good faith in damage calculations
• Get a Good Faith Compliance Certificate immediately
Technical Defenses:
• Some alleged violations may not actually exist
• Automated scanning tools produce false positives
• Manual testing may reveal site is more accessible than claimed
Settlement Considerations:
• Most Manning Law cases settle for $25,000-$60,000 total
• Fighting to trial costs $75,000-$150,000+ in legal fees
• Settlement often includes confidentiality provisions
• Weigh economics carefully
If You Have an Overlay Widget Installed:
• Overlays do NOT provide legal protection
• 22.6% of sued websites had overlays in 2025
• FTC fined AccessiBe $1M for false compliance claims
• Do NOT rely on overlay as defense
Proactive Protection: How to Avoid Being Targeted
The most cost-effective strategy is making your website accessible BEFORE Manning Law plaintiffs discover it. Here is your proactive protection roadmap:
IMMEDIATE PRIORITY: Fix High-Risk Violations
These violations are most commonly cited in Manning Law complaints:
1. Missing Alt Text on Images (cited in 67% of cases) • Add descriptive alt text to all meaningful images • Mark decorative images with empty alt="" • Ensure product images have descriptive names
2. Form Accessibility Issues (cited in 52% of cases) • All form fields must have associated labels • Error messages must be programmatically associated • Required fields must be indicated accessibly
3. Keyboard Navigation Failures (cited in 48% of cases) • All functionality must work with keyboard alone • Focus indicators must be visible • No keyboard traps
4. Color Contrast Issues (cited in 44% of cases) • Text must have 4.5:1 contrast ratio • Use WebAIM Contrast Checker to verify
5. Missing Page Structure (cited in 38% of cases) • Proper heading hierarchy (H1, H2, H3) • Landmarks for navigation • Skip links to main content
ONGOING PROTECTION:
• Quarterly accessibility scans (use our free scanner)
• Annual professional audit by WCAG experts
• Staff training on accessible content creation
• Procurement policies requiring vendor accessibility
• Accessibility statement with contact information
• Document everything for good faith defense
RISK ASSESSMENT:
You face elevated Manning Law risk if:
• You operate e-commerce in California or sell to CA residents
• Your website has obvious automated-scan-detectable issues
• You are in retail, restaurant, or travel industries
• Your annual revenue exceeds $5 million
• You have no documented accessibility program
The Broader Context: Serial Plaintiff Litigation Economics
Manning Law's prolific filing activity reflects the economics of ADA website litigation under current law:
Why Serial Plaintiff Litigation Exists:
• No government enforcement: DOJ has limited resources to enforce web accessibility
• Private right of action: ADA allows individuals to sue directly
• California Unruh Act: $4,000 minimum damages per violation creates financial incentive
• Attorney fee shifting: Prevailing plaintiffs recover fees, making low-value cases viable
• Settlement pressure: Defending costs more than settling
The Numbers:
• Average settlement: $25,000-$60,000
• Average defense cost if litigated: $75,000-$150,000
• Plaintiff attorney investment per case: $2,000-$5,000
• ROI for plaintiff attorneys: 5x-15x per case
Critics' Perspective:
Critics argue that serial plaintiff litigation:
• Enriches attorneys more than disabled individuals
• Targets small businesses with limited resources
• Uses technical violations that may not cause real harm
• Creates shakedown dynamics
Advocates' Perspective:
Disability rights advocates counter that:
• Websites genuinely fail people with disabilities
• Private enforcement fills regulatory void
• Settlements fund ongoing accessibility work
• Businesses have had decades to comply voluntarily
The Reality:
Regardless of one's view on the litigation model, the practical reality is clear: websites with accessibility barriers WILL be targeted. The question is not whether serial plaintiff litigation is fair, but how to protect your organization from it.
Compliance is both the ethical choice and the economically rational choice.
Protect Your Organization Today
Manning Law plaintiffs systematically scan for accessibility violations. Get ahead of them with a comprehensive accessibility assessment and documented good faith compliance efforts. Our scanner identifies the exact issues they target.
Get Your Free Accessibility ScanManning Law, APC has become the dominant force in ADA website accessibility litigation, filing 14% of all federal cases in 2025 through a small group of serial plaintiffs. Their success stems from the *Robles v. Domino's* precedent they established and California's Unruh Act, which provides $4,000+ minimum damages per violation.
For organizations, the takeaway is clear: proactive accessibility compliance costs far less than reactive litigation defense. A $50,000-$100,000 comprehensive accessibility remediation program prevents $25,000-$60,000 settlements that may recur annually if underlying issues remain unfixed.
Start with understanding your current accessibility posture through a comprehensive scan. Document all compliance efforts for good faith defense. Fix the high-priority violations (alt text, forms, keyboard navigation) that appear in most Manning Law complaints. And if you receive a lawsuit, engage experienced ADA defense counsel immediately.
The serial plaintiff litigation model will continue as long as websites remain inaccessible. The only way out is through: make your website accessible, document your efforts, and remove yourself from the target list.