ADA Compliance for Missouri Businesses

This guide explains how Title I (reasonable accommodation and the interactive process) and Title III (barrier removal and the readily achievable standard) work, why website-accessibility lawsuits are a growing risk, how service-animal rules apply, and where the MHRA differs from the federal floor. The key point: the ADA sets a federal minimum, and the MHRA can reach businesses the ADA does not.

What is the ADA, and which parts apply to a business?

The Americans with Disabilities Act is a comprehensive federal civil-rights law prohibiting discrimination against people with disabilities. Two of its "titles" matter most for a private Missouri business: Title I (Employment), which bars disability discrimination in the terms of employment and requires reasonable accommodation (enforced by the EEOC); and Title III (Public Accommodations), which bars discrimination against the public at restaurants, stores, hotels, doctors' offices, gyms, and the like and requires removing access barriers where readily achievable (enforced by the U.S. Department of Justice (DOJ) and through private lawsuits). Because the ADA is federal law, it applies in Missouri exactly as elsewhere, and the MHRA sits on top of it.

A threshold concept under both laws is disability itself, defined broadly as a physical or mental impairment that substantially limits a major life activity, a record of one, or being regarded as having one. Congress directed that this be construed in favor of broad coverage, so do not assume a condition "doesn't count" simply because it is managed by medication.

Who is covered by Title I (employment)?

Title I applies to private employers with 15 or more employees. If your business has fewer than 15, the federal ADA's employment provisions generally do not reach you — but the MHRA may, because it applies to Missouri employers with six or more employees. A business too small for the federal ADA can still owe obligations under RSMo Chapter 213 — one of the most important federal-versus-state gaps for Missouri employers.

Title I protects a qualified individual with a disability — someone who, with or without reasonable accommodation, can perform the essential functions of the job. Key obligations include:

• No disability-based discrimination in hiring, compensation, advancement, training, discipline, or discharge.
• Reasonable accommodation of a known disability, absent undue hardship.
• Limits on medical inquiries and exams , and confidentiality of medical information — generally no disability questions before a conditional job offer.

Reasonable accommodation and undue hardship

A reasonable accommodation is a change to the job, workplace, or usual way of doing things that lets a qualified employee perform the job or enjoy equal benefits — a modified schedule, leave beyond standard policy, assistive equipment, an accessible workstation, or reassignment to a vacant position.

An employer need not provide one that would cause an undue hardship — significant difficulty or expense judged against the cost and the employer's size and resources; what is undue for a five-person shop may be routine for a large company. An employer is also not required to remove an essential function, lower a legitimate production standard, or grant the employee's preferred option when an effective alternative exists.

The interactive process

When an employee or applicant requests an accommodation — or when the need is obvious — the ADA contemplates an interactive process: a good-faith, back-and-forth dialogue to identify the limitation and an effective accommodation. There is no magic-words requirement; an employee need not say "ADA," and a plain request can trigger the employer's obligation to engage.

Failing to engage in good faith is, by itself, a frequent source of liability. Employers should treat a request promptly; engage in dialogue rather than issuing a flat denial; request supporting documentation only when the need is not obvious, and keep it confidential; document the request, options, and outcome; and either provide an effective accommodation or document the specific basis for any undue-hardship claim.

What does Title III (public accommodations) require?

Title III prohibits a place of public accommodation from discriminating against people with disabilities in the "full and equal enjoyment" of its goods, services, and facilities. In practical terms, a Missouri business open to the public must:

• Not exclude or treat people differently because of a disability.
• Remove architectural barriers in existing buildings where removal is readily achievable — easily accomplishable without much difficulty or expense.
• Make reasonable modifications to policies and procedures when needed, unless that fundamentally alters the goods or services.
• Provide auxiliary aids and services — interpreters, large-print materials, assistive listening — for effective communication, unless an undue burden or fundamental alteration.

"Readily achievable" versus new-construction standards

Title III applies different standards depending on when a facility was built. For existing buildings, the obligation is to remove barriers where readily achievable — a ramp, accessible parking striping, grab bars — with what counts depending on cost and the business's resources (a national chain is expected to do more than a small storefront). New construction and major alterations, by contrast, must comply with the ADA Standards for Accessible Design, the detailed federal specifications for door widths, ramp slopes, and accessible routes — a stricter standard.

For example, suppose you own a 1980s café with a single step at the entrance and a too-narrow restroom door. Because the building predates the ADA, the step is judged by whether removal is readily achievable — a small ramp usually is. Widening the restroom doorway is costlier; if a full retrofit is not readily achievable, the law still expects alternative methods where feasible. But a newly built patio must meet the full ADA Standards from the start: existing barriers are judged by what is feasible for your business, while anything you newly build is held to the full technical standard.

Are websites covered by the ADA?

This is one of the fastest-moving areas of ADA litigation, and the law is still developing. The ADA predates the modern web and contains no explicit website provision. Courts have split, but a large and growing body of decisions — and the DOJ's longstanding position — treats the websites of public accommodations as subject to Title III, especially where the site connects to a physical business (a "nexus"). The result is a wave of website-accessibility lawsuits and demand letters, and Missouri businesses are not immune.

Because no single federal regulation specifies how a private business's site must be coded, courts and settlements overwhelmingly look to the Web Content Accessibility Guidelines (WCAG) — a widely used international standard — as the practical benchmark. WCAG is not a statute and conformance is not a guaranteed safe harbor, but WCAG conformance (commonly the latest version at the AA level) is the de facto target. Practical steps include alt text, keyboard and screen-reader compatibility, sufficient color contrast, clearly labeled forms, captioned video, and a published accessibility statement. Because this area is unsettled, treat the above as general information about trends, not a fixed rule.

What are the rules for service animals?

Under Title III, a service animal is defined narrowly: a dog (and, in limited circumstances, a miniature horse) individually trained to do work or perform tasks for a person with a disability — guiding someone who is blind, alerting to a seizure, retrieving items, and the like. Key points for a Missouri business:

• You generally must allow service animals wherever customers are normally allowed, even under a "no pets" policy.
• You may ask only two questions when the need is not obvious: Is the animal required because of a disability? And what work or task has it been trained to perform? You may not ask about the disability, demand documentation, or require a demonstration.
• Emotional-support and comfort animals are not "service animals" under Title III, because they are not trained for a specific task (different rules apply under separate housing and air-travel laws).
• You may remove an animal that is out of control or not housebroken — but must still serve the person without it.

Missouri also has its own service-dog and access laws, and misrepresenting a pet as a service animal can carry state-law consequences. When both apply, follow the more protective one.

How does the Missouri Human Rights Act differ from the ADA?

The Missouri Human Rights Act (RSMo Chapter 213) is Missouri's state-law counterpart to the ADA, independently prohibiting disability discrimination in employment and places of public accommodation and enforced by the Missouri Commission on Human Rights. It can reach situations the federal ADA does not. Key contrasts:

• Employer size. Title I covers employers with 15+ employees; the MHRA covers Missouri employers with 6+ — so a small employer exempt from the ADA can still be covered by the MHRA.
• Agency and deadlines. Federal claims go through the EEOC, state claims through the MCHR, and a charge is often dual-filed. An MHRA charge generally must be filed within a short window (commonly described as 180 days) and you typically need a right-to-sue letter before suing; EEOC deadlines run separately.
• Standard and remedies. Missouri amended the MHRA in recent years to change the plaintiff's legal standard and cap certain damages, so remedies are not identical to the ADA's.

The practical upshot: comply with the ADA as the federal floor, but check the MHRA too. One key remedy difference: under Title III, a private customer who hits a barrier generally can win only injunctive relief and attorneys' fees — not money damages (the DOJ can seek civil penalties), while under the MHRA monetary damages may be available, subject to Missouri's caps. That fee-driven dynamic fuels much accessibility and website litigation.

A practical ADA compliance checklist for Missouri businesses

No checklist guarantees compliance, but these steps address the most common risks under both laws:

1. Confirm which laws apply. Count employees: 15+ means Title I applies; 6+ means the MHRA likely applies. If you serve the public, assume Title III applies.
2. Audit your physical space. Check parking, entrance, route, counter, and restroom barriers; prioritize readily achievable fixes in existing buildings, and hold any remodel or new build to the full ADA Standards for Accessible Design.
3. Audit your website against WCAG (latest version, AA level): alt text, keyboard and screen-reader compatibility, and a published accessibility statement.
4. Adopt an accommodation procedure. Train managers to recognize requests, engage in the interactive process in good faith, and keep medical information confidential.
5. Train front-line staff on service animals — the two permissible questions and how to handle an out-of-control animal.
6. Document everything and respond fast. Keep records of audits, fixes, and accommodation discussions, and treat any complaint, charge, or demand letter as time-sensitive.

When should you talk to a Missouri attorney about ADA compliance?

Disability law is fact-specific and the federal and state pieces interlock, so it is worth getting advice when you receive an EEOC charge, MCHR complaint, or ADA/website demand letter (these carry short deadlines), when an accommodation request raises a hard reasonable-versus-undue-hardship call, or when a barrier may not be readily achievable to remove. An attorney can confirm which laws apply and identify the federal and Missouri deadlines that govern any claim.

Frequently Asked Questions