Websites as “Places of Public Accommodation”: Amending the Americans with Disabilities Act in the Wake of National Federation of the Blind v. Target Corporation

Abstract

The question of whether Title III of the Americans with Disabilities Act does or should apply to websites has been an issue of public interest since the advent of the Internet. In National Federation of the Blind v. Target Corporation, the Ninth Circuit was the first to find that Title III did apply to a website. Although Target was based on a specific set of facts, the decision highlights the need for Congress to amend the Act to address websites. This Recent Development explains why it is appropriate for Congress to take action now and examines several possible approaches Congress could take in amending the Act to address its application to websites.