Ohio presents a unique ADA website accessibility landscape. With 3,084 government entities facing the April 2026 compliance deadline and a legal environment shaped by the Sixth Circuit's 'nexus' requirement, Ohio entities must understand both the opportunities and risks they face.
The numbers are significant: 20 documented lawsuits with $46,000 average settlements, headlined by the Miami University case that resulted in over $260,000 in damages. Toledo, Cleveland, Columbus, and Cincinnati have all seen enforcement activity, and the DOJ has previously settled with the City of Toledo over accessibility violations.
But Ohio's position in the Sixth Circuit provides some nuances that entities should understand. This guide explains Ohio's specific legal environment, the nexus requirement, documented cases including Toledo-area enforcement, and what your entity must do before April 2026.
The Miami University Case: Ohio's Landmark Settlement
The most significant Ohio digital accessibility case involved Aleeha Dudley, a blind student who sued Miami University of Ohio. The case resulted in one of the largest educational institution accessibility settlements in the country.
What Happened:
Dudley, a blind student, filed a complaint alleging that Miami University's website, learning management system, and digital course materials were inaccessible to screen reader users. She could not:
• Access course materials in Canvas LMS
• Navigate the university website independently
• Complete online assignments and assessments
• Access library digital resources
The DOJ Intervened:
The U.S. Department of Justice became involved, investigating the university's digital accessibility practices. This federal involvement escalated the case significantly.
Settlement Terms:
• Educational compensation: $108,000
• Student loan repayment: $50,000
• Damages: $102,000
• Dudley Total: $260,000+
• Pool for other affected individuals: $25,000
• Total Settlement Value: $285,000+
Additional Requirements:
• Make ALL web content WCAG 2.0 AA compliant
• Remediate learning management system
• Train faculty on accessible content creation
• Establish accessibility office with dedicated staff
• Submit to DOJ monitoring for compliance
Why This Case Matters:
The Miami University settlement demonstrates: 1. Ohio entities CAN face massive settlements 2. DOJ will intervene in Ohio cases 3. Educational institutions are high-priority targets 4. Digital learning accessibility is enforceable 5. Individual harm can result in six-figure personal awards
For Ohio government entities and school districts, this case should eliminate any assumption that Ohio is a 'safe' state for accessibility non-compliance.
Toledo-Area Enforcement: Local Cases
Toledo and Northwest Ohio have seen documented ADA accessibility enforcement, demonstrating that the region is not immune to litigation:
City of Toledo DOJ Settlement:
The U.S. Department of Justice previously reached a settlement agreement with the City of Toledo requiring ADA Title II compliance. The city was required to:
• Publish ADA compliance notices on their website
• Publish notices in local newspapers
• Establish complaint procedures
• Ensure program accessibility
This settlement predates the current web accessibility focus but demonstrates DOJ's willingness to enforce in Toledo.
Toledo Metro Credit Union Case:
In *Mitchell v. Toledo Metro Credit Union* (N.D. Ohio 2018), a plaintiff filed an ADA website accessibility claim. While the case was dismissed because the plaintiff was not eligible to join the credit union (lacking standing), it demonstrates:
• Plaintiffs ARE filing website accessibility claims in Toledo
• Northwest Ohio is on the litigation map
• Standing requirements can provide defense in some cases
• But government entities face clearer standing (any resident can sue)
Regional Risk Factors:
Toledo-area entities face specific risk factors:
• University of Toledo and BGSU create academic accessibility awareness
• ProMedica and Mercy Health systems set digital accessibility standards
• Glass City's manufacturing legacy includes significant disabled workforce
• Northwest Ohio aging population requires accessible government services
Who Is At Risk in Toledo Area:
• City of Toledo government
• Lucas County government
• Toledo Public Schools
• Wood County, Sandusky County, Ottawa County
• Port of Toledo/Toledo-Lucas County Port Authority
• Regional transit (TARTA)
• All municipalities: Sylvania, Oregon, Maumee, Perrysburg, Bowling Green
Ohio's Sixth Circuit Advantage: The Nexus Requirement
Ohio falls within the Sixth Circuit Court of Appeals, which has adopted a 'nexus' requirement for ADA Title III website accessibility claims. This provides some protection for Ohio businesses, though government entities face different rules.
What Is the Nexus Requirement?
The Sixth Circuit requires that a website have a 'nexus' (connection) to a physical place of public accommodation for ADA Title III to apply. This means:
• Pure e-commerce sites with no Ohio physical presence may face fewer Title III risks
• Businesses with physical locations in Ohio ARE clearly liable
• The website must be connected to goods/services at a physical location
Why This Matters (And Doesn't) for Government:
For Private Businesses in Ohio:
• Online-only businesses may have nexus defense
• Brick-and-mortar businesses with websites clearly liable
• Sixth Circuit more defendant-friendly than 1st, 2nd, 7th, 9th Circuits
For Government Entities:
• Title II (government) has DIFFERENT rules than Title III (private)
• Government entities ARE places of public accommodation by definition
• No nexus requirement for government websites
• DOJ's April 2024 final rule explicitly requires government web accessibility
• Ohio government entities CANNOT rely on nexus defense
The Bottom Line:
While Ohio's Sixth Circuit position provides some protection for private online businesses, government entities have no such shield. The April 2026 deadline applies regardless of circuit court interpretations of Title III.
State Policy IT-09 (January 2025):
Ohio's own Digital Accessibility policy (effective January 10, 2025) requires all state agencies to make public websites and mobile apps WCAG 2.1 Level A and AA compliant. This state requirement reinforces federal obligations.
Scan Your Ohio Government Website
Ohio entities cannot rely on Sixth Circuit nexus rules for protection. Government websites must meet WCAG 2.1 AA standards by April 2026. Our free scanner identifies the violations that trigger lawsuits.
Scan Your Website NowOhio Entity Compliance Requirements
Ohio's government structure creates significant compliance obligations:
By the Numbers:
• Total government entities: 3,084
• Cities: 938
• Counties: 88
• School districts: 608
• Special districts: 1,450
April 24, 2026 Deadline (Population 50,000+):
Counties:
• Cuyahoga County (Cleveland): $74,000 documented settlement
• Franklin County (Columbus)
• Hamilton County (Cincinnati)
• Summit County (Akron)
• Montgomery County (Dayton)
• Lucas County (Toledo)
• 8 additional counties over 50,000
Cities:
• Columbus, Cleveland, Cincinnati, Toledo, Akron
• Dayton, Parma, Canton, Youngstown, Lorain
• 40+ additional cities over 50,000
School Districts:
• Columbus City Schools: $63,000 documented settlement
• Cleveland Metropolitan School District
• Cincinnati Public Schools
• Toledo Public Schools
• 100+ districts serving 50,000+ combined
Universities:
• Ohio State University
• University of Cincinnati
• University of Toledo
• Kent State University
• All community colleges
April 26, 2027 Deadline (Under 50,000):
• Remaining 74 counties
• 890+ smaller cities and villages
• 500+ smaller school districts
• Hundreds of townships
• Special districts (libraries, parks, utilities)
Ohio Compliance Action Plan
With State Policy IT-09 in effect and federal deadline approaching, Ohio entities need immediate action:
IMMEDIATE (This Week):
1. Run Accessibility Scan • Use our free scanner for baseline assessment • Document current state for good faith evidence • Identify critical violations
2. Inventory Digital Properties • Main website and subdomains • Online services (payments, permits, records) • PDF document libraries • Third-party embedded content
3. Review State Policy IT-09 • Effective January 10, 2025 • Requires WCAG 2.1 Level A and AA • Accessibility statements on all homepages • Third-party vendor compliance required
SHORT-TERM (30-90 Days):
4. Professional Audit • Hire WCAG 2.1 specialists (not overlay vendors) • Manual testing with assistive technology • Detailed violation inventory • Prioritized remediation roadmap
5. Budget Allocation • Website remediation: $35,000-$125,000 • PDF accessibility: $15,000-$60,000 • Ongoing monitoring: $10,000-$20,000/year • Compare to $46,000 average settlement + legal fees
6. Leadership Buy-In • Present Miami University case ($260k+) • Show local settlement data • Emphasize federal deadline • Request emergency funding if needed
MEDIUM-TERM (3-12 Months):
7. Systematic Remediation • Priority 1: High-traffic services (payments, applications) • Priority 2: PDF documents (forms, reports, minutes) • Priority 3: All remaining WCAG violations
8. Staff Training • Content creators on accessible authoring • IT staff on technical requirements • Procurement staff on vendor requirements
9. Policy Implementation • Accessibility governance policy • Procurement accessibility requirements • Content publishing standards • Complaint handling procedures
Build Your Ohio Good Faith Defense
Ohio courts consider documented good faith efforts. The Miami University case shows consequences of non-compliance. Get your accessibility assessment documented with a compliance certificate.
Get Compliance DocumentationOhio's ADA website accessibility landscape combines significant risk with some unique legal considerations. The Miami University $260,000+ settlement demonstrates that Ohio entities can face substantial liability. Toledo-area enforcement, including the City of Toledo DOJ settlement and Toledo Metro Credit Union lawsuit, shows Northwest Ohio is on the litigation map.
While Ohio's Sixth Circuit position provides some nexus-based protection for private online businesses, government entities have no such shield. The DOJ's Title II final rule explicitly requires WCAG 2.1 Level AA compliance for all state and local government websites by April 2026.
Ohio's own State Policy IT-09, effective January 2025, reinforces these requirements at the state level. Ohio government entities face dual federal and state compliance obligations.
The path forward is clear: conduct accessibility assessments now, document all compliance efforts, prioritize high-impact remediation, and achieve WCAG 2.1 AA compliance before the April 2026 deadline. The 3.8 million Ohioans with disabilities deserve accessible government services, and the legal requirements now make this obligation explicit.
Start with a comprehensive accessibility scan to understand your current state. Then follow the remediation roadmap to protect your entity and serve all Ohio residents effectively.