Updated November 2026 · Written and maintained by the Progression Agency strategy team
Web design in San Diego has its own court case. In 2020 a California Court of Appeal revived a blind man’s claim that San Diego County Credit Union’s website blocked his screen reader, and the complaint reads like a ticket list: missing alternative text, empty links, redundant links, missing form labels. Here is that story, what later courts added, how to build Spanish pages properly, what biotech and defense suppliers can say on a site, and what it all costs. It is general information, so ask counsel about your own site. Progression is a New York City firm that works with San Diego clients remotely, opening with a free proposal and a written scope.
On this page · 11 sections
- Web design in San Diego, and the lawsuit over a credit union’s website
- What Martinez v. San Diego County Credit Union decided
- What later California courts added
- Website design company San Diego buyers can brief from the complaint
- Spanish pages are a build question
- What a San Diego biotech can say on its site
- What a defense supplier can say about CMMC
- San Diego website design beyond the courtroom
- Questions for counsel before a redesign
- Web design services San Diego firms can price against
- Related services
The short answer The 2020 opinion in Martinez v. San Diego County Credit Union let a blind man’s claim about a website go forward, and it turned a list of four alleged barriers into a useful brief for any site: alternative text, links, labels. The court decided only that the allegations were enough at the pleading stage, and it left several questions open. Build Spanish pages on their own addresses, keep medical and defense claims to what the rules allow, and ask counsel about your own site. We are in New York City and work with San Diego clients remotely.
The Court of Appeal’s opinion, a second California decision, the Civil Rights Department’s FAQ, Google’s guidance on multilingual sites and the federal regulations were each opened on the sites that publish them in November 2026, and all of them can change. This page reports a court opinion and agency text. It is not legal advice and it predicts no outcome for any business.
Web design in San Diego, and the lawsuit over a credit union’s website
The story starts in July 2017, when a blind man who uses screen reading software filed a complaint against San Diego County Credit Union under the Unruh Civil Rights Act. The Court of Appeal’s opinion says he alleged that the website could not be read with his software because it contained four kinds of defect: missing alternative text, empty links, redundant links and missing form labels. He sought $4,000 per violation, an injunction limited to spending no more than $50,000 on corrections, and attorney fees and costs not to exceed $74,999. Those are what one plaintiff asked for, not a prediction of what anyone would pay.
The trial was set for November 2018. On the day scheduled for jury selection, the Superior Court of San Diego County dismissed the case on its own motion, reasoning that the plaintiff had not sufficiently alleged that a website is a public accommodation under the federal Americans with Disabilities Act. On June 19, 2020 the Court of Appeal, Fourth District, Division One, reversed. Everything above about the website is an allegation. The opinion did not find the credit union’s site inaccessible, and it did not decide that the credit union did anything wrong.
What Martinez v. San Diego County Credit Union decided
The court decided that the plaintiff’s allegations were enough, at the pleading stage, to state a claim, and that the trial court was wrong to dismiss on the reasoning it used. It went no further. The opinion is certified for publication, at 50 Cal.App.5th 1048.
The nexus test, in the court’s terms
The court said the federal circuits’ majority view, and a California Court of Appeal decision, allow a plaintiff to state an ADA claim over a private business’s website if there is a sufficient nexus between the alleged barriers and the plaintiff’s ability to use or enjoy the goods and services at the business’s physical facilities. It said the website need not be necessary to obtain those goods and services. Here the plaintiff alleged that the site let customers research and prepare before visiting, locate the facilities and understand products and services, and the court found that enough for the pleading stage.
Does the ruling mean every site is covered?
No. It decided that these allegations, about a business with physical locations, were enough to go forward. It said nothing about a business with no physical place, and later decisions point both ways, which is why the next section matters.
- It reversed a dismissal; it did not decide who wins.
- It treated the four defects as allegations, not findings.
- It tied the claim to a website’s connection to physical locations.
- It left open coverage with no physical connection.
- It sent the case back to the trial court.
No federal web standard was no defense
The credit union argued that dismissal was proper because Congress has not enacted specific website accessibility standards. The court rejected that. It said courts have the authority to interpret the ADA and apply it to website accessibility even without those standards, and it agreed with the reasoning of the Ninth Circuit’s Robles v. Domino’s Pizza decision and a California Court of Appeal’s Thurston v. Midvale Corp. decision, both from 2019.
What the opinion left open
The court did not decide whether a website is covered by the ADA with no nexus to a physical place. It did not decide whether the intentional discrimination theory stands, which it said the plaintiff may pursue on remand if supported by the facts and if the trial court finds no forfeiture. It did not decide whether the allegations are true, what remedies would be right, or the credit union’s objections to the Web Content Accessibility Guidelines, which the court called outside the appellate record and not yet ripe. The case went back to the trial court. We did not read what happened next, so we say nothing about it.
What later California courts added
Two different people named Martinez brought accessibility cases against different businesses, which can confuse a first read. The 2020 case is against a credit union with physical locations. The 2022 case is against an online retailer. They are separate, and the table sets them side by side.
| Case | Court and date | The business | What it decided |
|---|---|---|---|
| Martinez v. San Diego County Credit Union | Fourth District, Division One, June 19, 2020 | A credit union with physical locations | Reversed a dismissal; allegations tying the website to the physical locations were enough at the pleading stage |
| Martinez v. Cot’n Wash, Inc. | Second District, Division One, August 1, 2022 | A retailer whose website has no physical space | Affirmed dismissal; the court could not read the ADA’s public accommodation phrase to include a retail website with no connection to a physical space |
Online-only retailers
In the Cot’n Wash opinion the court affirmed a dismissal. It said that under current law it could not read the phrase “place of public accommodation” in Title III of the ADA to include retail websites without any connection to a physical space, and that it could not infer intentional discrimination from a facially neutral website’s discriminatory effect plus inaction after notice. The California Civil Rights Department’s FAQ also cites Martin v. Thi E-Commerce, LLC, a 2023 decision, for online-only businesses; we did not read that opinion, so we rely on the department’s description.
Businesses with a physical location
The Civil Rights Department’s Unruh Act FAQ answers whether the Act requires accessible websites with “It depends.” It says courts have interpreted the accessibility provisions to apply to websites associated with businesses that have physical locations, and gives the example of a restaurant whose website must be compatible with screen reading software. It says courts have found online-only businesses are not places of public accommodation under the Act and encourages them to be accessible anyway. On remedies, it says they include actual damages, up to three times actual damages but not less than $4,000 for each offense, and attorney fees and costs. A San Diego buyer with a shop, branch, clinic or office should read this one.
The state and federal high courts
We found no ruling by the California Supreme Court or the United States Supreme Court on the website question when we checked in November 2026. That is a negative from searching, not a certainty, so ask counsel for the current position.
Website design company San Diego buyers can brief from the complaint
A website design company San Diego buyers hire can turn the four alleged defects into a brief. They are a floor for a brief, not a legal standard, and passing them proves nothing about the law. The table turns each allegation into a ticket a designer or developer can work on and a way to test it.
| Alleged barrier | What the opinion says it is | The ticket | How it is tested |
|---|---|---|---|
| Missing alternative text | Code under an image that lets a screen reader describe the graphic | Give each informative image a text alternative and mark decorative ones as decorative | Listen to the page with a screen reader and check that every image is announced sensibly |
| Empty links | Links that confuse keyboard and screen reader users | Give each link words that say where it goes | Tab through the page and review the list of links a screen reader offers |
| Redundant links | Extra links that add navigation and repetition | Merge adjacent links to the same address | Move through the links in order and note repeats |
| Missing form labels | A form control whose purpose may not reach screen reader users | Tie a real label to every field | Tab into each field with a screen reader and listen for its label |
Is passing the four tickets enough?
No. They are a floor for a brief, drawn from one complaint. A site can fix all four and still have other barriers, and no list from a court opinion settles what the law requires of your site. Full testing against a recognized standard comes next, and counsel decides what applies.
Our accessible website design page covers the full method; this page does not restate it. The two extra cards show practices that sit beside the four allegations, and none of them is a claim about what the law requires.
What a web development company in San Diego adds
A web development company in San Diego, or a San Diego web development company, builds what a template does not cover: portals, logins, calculators, booking and the parts that connect to other systems. Web development agency San Diego buyers shortlist, or a San Diego web development agency, should say who maintains those parts. San Diego web development companies and the San Diego web development company a smaller team might hire both need to test them with a keyboard and a screen reader. Someone searching for a San Diego website developer wants the same thing. For apps rather than sites, see our app development in San Diego page.
Does your San Diego business have a physical place, and what does the site connect to it?Tell us whether you have a physical location, what your site connects to it, and which languages you need. You get a free proposal for web design in San Diego with a written scope.
Spanish pages are a build question
People who search for web design San Diego Spanish pages are usually asking two things: how to build them and who should read them. The audience and the marketing belong on our marketing agency in San Diego page, and this one covers the build. The Civil Rights Department’s FAQ says the Unruh Act does not require a business to provide services or documents in a language other than English beyond what other federal, state or local laws require, including Civil Code section 1632, and that the department encourages businesses to offer them. Ask counsel about other laws that may apply.
One address for each language
Google’s guidance on multi-regional and multilingual sites recommends different URLs for each language version rather than cookies or browser settings, and hreflang annotations so search results link to the right version. The diagram shows address pairs. The Spanish pages mirror only the English pages you actually offer in Spanish.
No redirects by guesswork
The same guidance says not to redirect users automatically from one language version to another based on a guess about their language, and not to use IP analysis to adapt content. Show a visible link on every page that lets visitors choose, and let them stay where they land.
Forms, errors and alt text in both languages
Form labels and error messages are where a second language usually breaks. Every ticket in the table above applies twice: a Spanish form needs a Spanish label, a Spanish error message and Spanish alternative text on every informative image. A field that is labeled in English on a Spanish page is a barrier of its own.
Should every English page get a Spanish twin?
No. Translate the pages that matter to the people who need them, such as services, contact, prices and forms, and say plainly on the English side which pages exist in Spanish. A half-translated page with English buttons is worse than a clear, shorter Spanish section.
- Pick the pages that carry the sale or the service.
- Give each Spanish page an address under its own folder.
- Add the language link to the header of every page.
- Translate forms, errors and image descriptions along with the text.
- Name the person who updates each page when the English changes.
Who updates the second language?
Name one person for it. The content model should show which fields are translated, what happens when the English page changes and who approves the Spanish version. Without an owner, Spanish pages drift out of date within a season, and a stale page is worse than none.
What a San Diego biotech can say on its site
A clinical-stage company has one federal rule to know before writing a pipeline page. The eCFR’s 21 CFR 312.7(a) says a sponsor or investigator, or a person acting on their behalf, shall not represent in a promotional context that an investigational new drug is safe or effective for the purposes under investigation or otherwise promote the drug, and it says this is not meant to restrict the full exchange of scientific information. For how a pipeline page handles that line, see our biotech website design page. Page review should include someone who can read that rule and the copy side by side. Ask counsel.
What a defense supplier can say about CMMC
A supplier to the Department of Defense meets a second rule. The eCFR’s 32 CFR 170.3 says the Cybersecurity Maturity Model Certification requirements apply to DoD contract and subcontract awardees that process, store or transmit federal contract information or controlled unclassified information on contractor systems. It names the statuses Level 1 (Self), Level 2 (Self), Level 2 (C3PAO) and Level 3 (DIBCAC), and says DoD is phasing the requirements in over four phases, each beginning a year after the one before.
Our advice, which is advice and not a rule: use the exact status name you hold, with the date, and leave it off the site if you hold none. A line like “CMMC compliant” invites a question you may not want to answer. The San Diego Regional EDC’s home page lists a defense innovation roadmap, and we did not read it, so we describe no contents. Our government contractor marketing page covers the security and trust signals a supplier site can carry. Ask counsel.
Should a supplier show a CMMC badge?
Only if the status is real and the wording is exact. Use the status name as written in the rule, add the date, and link to nothing that implies more than you hold.
- State the exact status name, with the date.
- Leave the line off if you hold no status.
- Have counsel read the wording before it goes live.
- Keep the line in one place so it can be updated everywhere at once.
San Diego website design beyond the courtroom
San Diego website design is not only about accessibility. Web design in San Diego, CA comes in a dozen forms, and it still depends on speed, content and ownership, which each get a short paragraph here. Owners comparing quotes for website design in San Diego should ask about all three. Small business web design in San Diego should start with the smaller row that fits, and WordPress web design in San Diego suits teams that will edit their own pages; see our WordPress website design page.
Speed matters most on image-heavy pages and on a phone, so ask any firm for a mobile load target and how it measures it. Content decides whether a page answers the question a visitor came with, which is why it is written before the layout is finished. Ownership means the domain, hosting, editing system and files are in your name.
The best web design San Diego owners can find is the one whose site passes the tickets above when you test it; we do not rank firms. The web design San Diego buyers compare is easiest to judge by testing with a keyboard and a screen reader.
Questions for counsel before a redesign
A redesign is a good time to meet counsel. The list below is for that meeting. It is not legal advice, and it does not tell you what the answers are; it tells you what to bring.
- Do we have a physical place, and which site features connect customers to it?
- Do we rely on third-party widgets, and who answers for them?
- Who receives and responds to a demand letter?
- What do we say in an accessibility statement, and who keeps it current?
- Which pages exist in Spanish, and who is responsible for them?
Web design services San Diego firms can price against
Web design services San Diego firms offer are priced by pages, features and integrations, and no San Diego-only band is published. How much web designers charge in San Diego is therefore a national answer with a local label. Web design companies San Diego owners call will quote different things, and affordable web design in San Diego means a smaller scope, not a thinner build.
What do web designers charge in San Diego?
The same as designers elsewhere in the United States: the bands below, depending on pages, features and integrations. A San Diego label adds no published premium. What changes the number is scope, so ask each firm to list what its quote includes.
- The number of page templates and components.
- How many pages are written, not supplied.
- Integrations such as booking, portals or feeds.
- A second language and who keeps it current.
- Accessibility testing and fixes beyond the build.
Progression’s fixed fees
Our fixed-scope pricing on the website design and development page lists a starting price for each build type. We use it without change.
| Build type | Price from |
|---|---|
| Restyle in place | $4,800 |
| Landing page | $1,400 |
| Brochure site, 5 to 8 pages | $9,500 |
| Business site, 10 to 16 pages | $18,000 |
| Ecommerce, under 200 SKUs | $34,000 |
Published market bands, including accessibility work
The bands below come from other providers’ published pages and run from the typical low to the published high. None is a Progression quote and none is specific to San Diego. Website maintenance services in San Diego follow the care plan band. We state no price for a second language, because no band covers it.
| Work | Published US band | What it describes |
|---|---|---|
| Small business site | $3,000 to $25,000 | 5 to 15 pages |
| Custom business site | $15,000 to $100,000 | 20 to 60 pages, custom design and integrations |
| Enterprise site | $50,000 to $250,000 | Multi-site or headless builds |
| Online store | $5,000 to $100,000 | Small catalogs to large ones |
| Accessibility audit and fixes | $1,500 to $7,500 | Small to mid sites; large sites cost more |
| Care plan, monthly | $100 to $2,500 | Updates, backups, security and small edits |
Related services
Pages on the services around this one:
- Accessible website design
- Website design and development
- Biotech website design
- App development in San Diego
- Marketing agency in San Diego
- Web design companies by city
Get a free proposal
Tell us whether you have a physical location, what your site connects to it, and which languages you need. You get a free proposal for web design in San Diego with a written scope.
Getting found in search
AI, AEO and what is changing
Paid media and lead generation
Websites and design
Choosing and working with an agency
Software and app development
Website design by industry and type
Web development, platforms and hosting
Social, content and brand
By industry and by situation
Frequently asked questions
Why does web design in San Diego come with a court case attached?
What did the court decide in Martinez v. San Diego County Credit Union?
Did the court find the credit union’s website inaccessible?
Does the case apply to a San Diego business with no storefront?
Does the Unruh Act require a Spanish version of my site?
What are the money stakes under the Unruh Act?
What should a website design company in San Diego fix first?
Does WCAG decide whether a California site complies?
Is an accessibility overlay enough?
Should Spanish pages live on separate addresses?
Can a clinical stage company describe results on its site?
Can a supplier write CMMC compliant on its site?
What do web design services in San Diego cost?
Does Progression have a San Diego office?
What did the plaintiff ask for in Martinez?
Is there more than one Martinez accessibility case in California?
What does missing alternative text mean in practice?
What does phased in mean for CMMC?
What belongs in the statement a site publishes about its own accessibility?
Which details speed up a first conversation with you?
Does your San Diego business have a physical place, and what does the site connect to it?Tell us whether you have a physical location, what your site connects to it, and which languages you need. You get a free proposal for web design in San Diego with a written scope.
Get a free marketing proposal
Tell us what you are trying to grow and we will come back with a plan, not a pitch deck. Same-day reply on weekdays.