Federal Court Dismisses ADA Lawsuit Over Restaurant's Informational Website

On January 8, 2026, the United States District Court for the Eastern District of Missouri dismissed with prejudice an Americans with Disabilities Act (ADA) complaint against Mary Jane Bourbon & Chophouse, LLC. The court determined that a static, informational website is neither a place of public accommodation under Title III nor possesses the necessary nexus to the physical premises to support an ADA claim.

Case Background

The plaintiff, a blind individual who has filed nearly fifty ADA lawsuits in the Eastern District of Missouri over the past two years, filed suit alleging that Mary Jane Bourbon & Chophouse, LLC operated a website incompatible with screen-reading software. The defendant operates a restaurant in Cape Girardeau, Missouri. The plaintiff claimed to travel frequently to the area for fishing trips, eat at local restaurants, and intend to visit the establishment again.

According to the complaint, the plaintiff attempted to view the establishment's menu, drink options, hours of operation, location, and upcoming events to decide on a purchase at the physical location, but encountered significant digital accessibility barriers. After an initial motion to dismiss, the plaintiff filed a 31-page amended complaint, which the defendant again moved to dismiss under Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure.

Standing and Statutory Analysis

District Judge Matthew T. Schelp ruled that while the plaintiff met the modest threshold for Article III standing at the pleading stage, the claims failed as a matter of law under Title III of the ADA (42 U.S.C. § 12182(a)).

The court observed that 42 U.S.C. § 12181 lists twelve categories of public accommodations, all describing physical, tangible locations. Looking to statutory construction and decisions from other federal appellate circuits—including the Third, Sixth, Ninth, and Eleventh Circuits—the court concluded that websites by themselves are not places of public accommodation under the text of Title III.

Rejection of the Nexus Argument

The plaintiff asserted that even if websites are not independent public accommodations, the site satisfied the "nexus test" recognized by some jurisdictions, linking the website to a physical venue. The court rejected this argument on two fronts:

• Absence of Statutory Basis: The court found no textual foundation in the ADA for the nexus standard.
• Factual Distinctions: Even under a nexus framework, the defendant's website did not offer online ordering, deliveries, in-store pickup, or exclusive discounts (contrasting with cases such as Robles v. Domino's Pizza, LLC).

The court characterized the defendant's site as a static, digital equivalent of a brochure. The court noted that extending Title III to cover informational websites would logically require tactile roadside signs, Braille promotional flyers, and street promoters using sign language—an interpretation unsupported by the ADA's text, which does not confer a standalone "right to information."

Because the plaintiff retained meaningful access to dine at the restaurant on equal terms with sighted patrons, the action failed to state a claim. Any motion for attorney fees under 42 U.S.C. § 12205 must be filed no later than Thursday, January 22, 2026. Details of the ruling can be found in the court record.