Federal Court Dismisses ADA Suit Against GoDaddy Over Web Hosting and Account Access

On August 7, 2026, the United States District Court for the Eastern District of Pennsylvania dismissed an action brought under Title III of the Americans with Disabilities Act (ADA) against GoDaddy.com, LLC (Civil Action No. 26-CV-4700). The ruling reaffirmed that in the Third Circuit, purely digital services that lack a nexus to a physical space are not covered as public accommodations under the statute.

Background of the Dispute

The plaintiff, appearing pro se and acting as the executive director of a nonprofit organization named Bunny’s Flowers, Inc., initiated the case against GoDaddy on July 2, 2026. The action followed service and account disputes regarding website hosting, domain administration, account provisioning, disputed billing charges, and website deactivation.

According to the complaint, the plaintiff notified GoDaddy of disability-related limitations, requested email- or text-based communication, and sought assurances that the hosting account would remain active during ongoing recovery efforts. Despite an alleged statement from GoDaddy that the account would remain active for an additional 14 days to renew the plan, the nonprofit organization's website was taken down around December 25. While the website was later restored, the plaintiff alleged ongoing administrative disruptions and disputed billing that affected projects aimed at online accessibility training and ADA compliance awareness.

Alongside Title III ADA claims, the complaint raised state-law claims including breach of contract, breach of the covenant of good faith and fair dealing, negligence, conversion, and violations of Pennsylvania's Unfair Trade Practices and Consumer Protection Law, seeking unspecified monetary damages, injunctive relief, and emergency preservation of evidence.

Court's Analysis of ADA Title III

While granting the plaintiff leave to proceed in forma pauperis, the court conducted an initial statutory screening under 28 U.S.C. § 1915(e)(2)(B)(ii). The court dismissed the ADA claim with prejudice based on three core legal defects:

• Failure to Plead a Qualifying Disability: The complaint failed to allege factual details demonstrating that the plaintiff has an impairment that substantially limits one or more major life activities under 42 U.S.C. § 12102.
• No Place of Public Accommodation: The court highlighted that under binding Third Circuit precedent (such as Ford v. Schering-Plough Corp. and Peoples v. Discover Fin. Servs., Inc.), a "public accommodation" under 42 U.S.C. § 12181(7) requires a physical structure. Because GoDaddy's web-hosting, registration, and management tools operate strictly through electronic portals without a nexus to a physical location, the services do not constitute places of public accommodation under Title III.
• Lack of Causation: The court found no plausible allegation showing that GoDaddy’s actions or service interruptions occurred because of the plaintiff's disability, characterizing the issue as an ordinary data service dispute.

Dismissal and State Claims

Because the sole federal claim was dismissed with prejudice as futile, the court declined to exercise supplemental jurisdiction over the remaining state-law counts under 28 U.S.C. § 1367(c). Furthermore, the plaintiff failed to establish diversity jurisdiction under 28 U.S.C. § 1332(a) because the complaint did not allege the citizenship of the parties or demonstrate an amount in controversy exceeding the $75,000 statutory threshold.

The court denied the plaintiff’s motions for temporary restraining orders and emergency relief due to an inability to demonstrate a likelihood of success on the merits. The plaintiff was granted leave to file an amended complaint solely to plead adequate jurisdictional facts for the state-law claims, or otherwise bring those claims in state court.